T.C. Summary Opinion 2006-183                             
                               UNITED STATES TAX COURT                                
                   KEVIN J. & CRYSTAL A. SHOEMAKER, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 21275-04S.         Filed November 22, 2006.                 
               Kevin J. Shoemaker and Crystal A. Shoemaker, pro sese.                 
               James H. Harris, Jr., for respondent.                                  
               CHIECHI, Judge:  This case was heard pursuant to the provi-            
          sions of section 7463 of the Internal Revenue Code 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.                                                         
               1Hereinafter, all section references are to the Internal               
          Revenue Code in effect for the year at issue.  All Rule refer-              
          ences are to the Tax Court Rules of Practice and Procedure.                 
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