John B. Roberts, Jr., and Jean Roberts - Page 2

                            T.C. Summary Opinion 2005-40                              


                               UNITED STATES TAX COURT                                


               JOHN B. ROBERTS, JR., AND JEAN ROBERTS, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3049-03S.            Filed April 13, 2005.                  


               John B. Roberts, Jr., and Jean Roberts, pro se.                        
               Nancy E. Hooten, for respondent.                                       


               COUVILLION, Special Trial Judge: This case was heard                   
          pursuant to section 7463 in effect when the petition was filed.1            
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.  Petitioners             
          seek a review under section 6330(d) of respondent’s decision to             


               1Unless otherwise indicated, subsequent section references             
          are to the Internal Revenue Code in effect for the years at                 
          issue.                                                                      




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