J. McLean and Judy A. Durfey - Page 2

                            T.C. Summary Opinion 2006-151                             


                               UNITED STATES TAX COURT                                


                    J. MCLEAN AND JUDY A. DURFEY, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No.  22715-04S.          Filed September 14, 2006.              


               J. McLean and Judy A. Durfey, pro sese.                                
               R. Craig Schneider, for respondent.                                    


               DAWSON, Judge:  This case was heard pursuant to the                    
          provisions of section 7463 of the Internal Revenue Code in effect           
          when the petition was filed.  The decision to be entered is not             
          reviewable by any other court, and this opinion should not be               
          cited as authority.  Unless otherwise indicated, subsequent                 
          section references are to the Internal Revenue Code in effect for           
          the year in issue, and all Rule references are to the Tax Court             
          Rules of Practice and Procedure.                                            





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