Randy Gene and Kathie J. Shreve - Page 2

                            T.C. Summary Opinion 2006-101                             


                               UNITED STATES TAX COURT                                


                   RANDY GENE AND KATHIE J. SHREVE, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 1177-05S.              Filed July 10, 2006.                 


               Randy Gene and Kathie J. Shreve, pro se.                               
               Robert W. Dillard, for respondent.                                     

               WELLS, Judge:  This case was heard pursuant to the                     
          provisions of section 7463 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, all section references are to the Internal             
          Revenue Code, as amended.                                                   








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