Vitally V. and Svetlana N. Andrukov - Page 2















                            T.C. Summary Opinion 2007-46                              


                               UNITED STATES TAX COURT                                


                 VITALLY V. AND SVETLANA N. ANDRUKOV, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 5743-06S.               Filed March 21, 2007.               


               Vitally V. and Svetlana N. Andrukov, pro sese.                         
               Mark D. Eblen, for respondent.                                         


               COHEN, Judge:  This case was heard pursuant to section 7463            
          of the Internal Revenue Code in effect at the time the petition             
          was filed.  Unless otherwise indicated, all section references              
          are to the Internal Revenue Code in effect for the year in issue,           
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.  The decision to be entered is not reviewable by             








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