Jerry Jefferson Kirkeby and Ying Wang - Page 2

                            T.C. Summary Opinion 2006-180                             


                               UNITED STATES TAX COURT                                


                JERRY JEFFERSON KIRKEBY AND YING WANG, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 21371-05S.         Filed November 6, 2006.                  

               Jerry Jefferson Kirkeby and Ying Wang, pro sese.                       
               Jonathan A. Neumann, for respondent.                                   


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code.                
          Unless otherwise indicated, subsequent section references are to            
          the Internal Revenue Code as in effect for the year at 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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