Nelson I. and Esther S. Goodman - Page 1

                                 T.C. Memo. 2006-220                                  

                               UNITED STATES TAX COURT                                

                   NELSON I. AND ESTHER S. GOODMAN, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 21917-04L.            Filed October 23, 2006.               

               Martin D. Tropper, for petitioners.                                    
               Alex Shlivko, for respondent.                                          

                                 MEMORANDUM OPINION                                   

               DEAN, Special Trial Judge:   This case is before the Court             
          on respondent's motion for summary judgment filed pursuant to               
          Rule 121.  Rule references are to the Tax Court Rules of Practice           
          and Procedure.  Section references are to the Internal Revenue              
          Code of 1986 as amended.  The motion arises in the context of a             
          petition filed in response to a Notice of Determination                     

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