Larry J. and Catherine E. France - Page 2

                            T.C. Summary Opinion 2006-136                             


                               UNITED STATES TAX COURT                                


                  LARRY J. AND CATHERINE E. FRANCE, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3243-03S.             Filed August 30, 2006.                


               Larry J. France, pro se.                                               
               Bradley C. Plovan, for respondent.                                     

               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 74631 of the Internal Revenue Code             
          in effect at the time 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.                                           


               1    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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