Robert G. and Lana L. Gale - Page 2

                            T.C. Summary Opinion 2006-152                             


                               UNITED STATES TAX COURT                                


                     ROBERT G. AND LANA L. GALE, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 2088-06S.             Filed September 14, 2006.             


               Robert G. and Lana L. Gale, pro sese.                                  
               R. Craig Schneider, for respondent.                                    


               DAWSON, Judge:  This case was heard pursuant to 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.             



               1Unless otherwise indicated, subsequent section references             
          are to the Internal Revenue Code in effect for the year at issue.           
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  




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