Gary Lyle Gibson and Mirian Julia Alves - Page 2

                            T.C. Summary Opinion 2006-138                             


                               UNITED STATES TAX COURT                                


               GARY LYLE GIBSON AND MIRIAN JULIA ALVES, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 19638-05S.           Filed September 11, 2006.              


               Gary Lyle Gibson, pro se.                                              
               Brian A. Pfeifer, for respondent.                                      


               JACOBS, 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.  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.  The decision to be              
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           





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