T.C. Summary Opinion 2006-170
UNITED STATES TAX COURT
NADER GHAZITEHRANI AND FARZANEH ZAMANIZADEH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12653-05S. Filed October 23, 2006.
Nader Ghazitehrani and Farzaneh Zamanizadeh, pro sese.
Aimee R. Lobo-Berg, Thomas J. Travers, and Anna L. Rooney
(specially recognized), for respondent.
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7463 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. Unless otherwise
indicated, subsequent section references are to the Internal
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