William King Alt and Barbara G. Alt - Page 2

                            T.C. Summary Opinion 2006-96                              

                               UNITED STATES TAX COURT                                

                 WILLIAM KING ALT AND BARBARA G. ALT, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 19964-04S.             Filed June 27, 2006.                 

               William King and Barbara G. Alt, pro se.                               
               Alisha M. Harper, 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.                          

               1Unless otherwise indicated, section references hereafter              
          are to the Internal Revenue Code in effect for the year at issue.           
          All Rule references are to the Tax Court Rules of Practice and              

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