David E. Caruso, Jr. and Barbara Caruso - Page 2

                            T.C. Summary Opinion 2006-117                             


                               UNITED STATES TAX COURT                                


               DAVID E. CARUSO, JR. AND BARBARA CARUSO, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 17087-04S.             Filed July 24, 2006.                 


               David E. Caruso, Jr., and Barbara Caruso, pro se.                      
               Scott T. 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 6330(d) 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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