Gary C. and Maru E. Johansen - Page 2

                            T.C. Summary Opinion 2006-126                             

                               UNITED STATES TAX COURT                                

                    GARY C. AND MARU E. JOHANSEN, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6643-05S.            Filed August 10, 2006.                 

               Gary C. and Maru E. Johansen, pro sese.                                
               Gavin L. Greene, for respondent.                                       

               DEAN, 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.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code of 1986, as amended, 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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