Emmanuel & Cecilia Abloso - Page 2

                            T.C. Summary Opinion 2006-60                              


                               UNITED STATES TAX COURT                                


                     EMMANUEL AND CECILIA ABLOSO, Petitioners v.                      
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                     


               Docket No. 898-04S.             Filed April 19, 2006.                  


               Emmanuel and Cecilia Abloso, pro se.                                   
               Guy Glaser, Kim-Khanh Thi Nguyen, and Sherri S. Wilder,                
          for respondent.                                                             


               CARLUZZO, Special Trial Judge:  This case for the                      
          redetermination of a deficiency was heard pursuant to the                   
          provisions of section 7463 of the Internal Revenue Code in effect           
          at the time the petition was filed.  Unless otherwise indicated,            
          subsequent section references are to the Internal Revenue Code in           
          effect for 2000.  Rule references are to the Tax Court Rules of             






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