Emmanuel M. and Blessing N. Nwankwo - Page 2

                            T.C. Summary Opinion 2006-187                             


                               UNITED STATES TAX COURT                                


                 EMMANUEL M. AND BLESSING N. NWANKWO, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 3981-05S, 8353-05S.   Filed December 12, 2006.             

               Emmanuel M. and Blessing N. Nwankwo, pro sese.                         
               Robert Mopsick, for respondent.                                        


               GOLDBERG, Special Trial Judge:  These consolidated cases               
          were heard pursuant to the provisions of section 7463 of the                
          Internal Revenue Code in effect at the time the petitions were              
          filed.  The decisions to be entered are not reviewable by any               
          other court, and this opinion should not be cited as authority.             
          Unless otherwise indicated, subsequent section references are to            
          the Internal Revenue Code in effect for the years at issue, and             
          Rule references are to the Tax Court Rules of Practice and                  





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