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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