Lawrence K. and Ruth L. Harrell - Page 2

                            T.C. Summary Opinion 2006-165                             


                               UNITED STATES TAX COURT                                


                   LAWRENCE K. AND RUTH L. HARRELL, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 17918-05S.            Filed October 16, 2006.               

               Ruth L. Harrell, 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 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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