T.C. Summary Opinion 2006-76
UNITED STATES TAX COURT
RONALD AND BARBARA CARTER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8430-04S. Filed May 10, 2006.
Ronald and Barbara Carter, pro se.
Scott Thomas Welch, 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 6320 of respondent’s decision to
1Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the year at issue.
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