Terrance LaShawn and Christy Shields - Page 2

                            T.C. Summary Opinion 2006-192                             


                               UNITED STATES TAX COURT                                


                TERRANCE LASHAWN AND CHRISTY SHIELDS, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 23815-05S.         Filed December 21, 2006.                 


               Terrance LaShawn and Christy Shields, pro sese.                        
               James H. Brunson III, for respondent.                                  


               WELLS, 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.  All subsequent section references are to            
          the Internal Revenue Code in effect for the year in issue, and              








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