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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