William H. and Sandra G. Flank - Page 2

          T.C. Summary Opinion 2006-134                                               


                               UNITED STATES TAX COURT                                


                   WILLIAM H. AND SANDRA G. FLANK, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 11503-05S.            Filed August 29, 2006.                


               William H. and Sandra G. Flank, pro sese.                              
               Michelle L. Maniscalco, for respondent.                                


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code as in           
          effect at the time the petition was filed.  Unless otherwise                
          indicated, all 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.  The decision             







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