Jayesh B. and Devsmita J. Patel - Page 2

                            T.C. Summary Opinion 2006-40                              


                               UNITED STATES TAX COURT                                


                   JAYESH B. AND DEVSMITA J. PATEL, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 11530-04S.            Filed March 16, 2006.                 

               Jayesh B. and Devsmita J. Patel, pro sese.                             
               Clare J. Brooks, for respondent.                                       


               GOLDBERG, 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.  The decision to be              
          entered is 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 year in issue.                                               







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