Richard C. and Mary Jo Runyan - Page 2

                            T.C. Summary Opinion 2006-58                              


                               UNITED STATES TAX COURT                                


                    RICHARD C. AND MARY JO RUNYAN, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4124-04S.            Filed April 19, 2006.                  

               Richard S. Avellone, for petitioners.                                  
               Steven W. LaBounty, for respondent.                                    


               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 in effect at the time the petition was             
          filed.1  The decision to be entered is not reviewable by any                
          other court, and this opinion should not be cited as authority.             
               Respondent determined a deficiency of $3,057 in petitioners’           
          2001 Federal income tax.                                                    



               1Unless otherwise indicated, subsequent section references             
          are to the Internal Revenue Code in effect for the year at issue.           




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