Gary and Cynthia Stein - Page 2

                            T.C. Summary Opinion 2006-179                             


                               UNITED STATES TAX COURT                                


                       GARY AND CYNTHIA STEIN, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


          Docket No. 23179-04S.              Filed November 2, 2006.                  


               Gary and Cynthia Stein, pro sese.                                      
               Carolyn E. Moran, for respondent.                                      


               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7463 in effect when 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.             
          This case arises from a petition for judicial review filed in               


               1Unless otherwise indicated, subsequent section references             
          are to the Internal Revenue Code, as amended.                               





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