William Edward and Patricia Marie Colombell - Page 2

                            T.C. Summary Opinion 2006-184                             


                               UNITED STATES TAX COURT                                


             WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v.              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 23979-04S.         Filed November 30, 2006.                 

               William Edward and Patricia Marie Colombell, pro sese.                 
               Deborah C. Stanley, for respondent.                                    


               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code 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.                                                      


               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2002,             
          the taxable year in issue.                                                  




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