T.C. Summary Opinion 2007-189
UNITED STATES TAX COURT
HECTOR F. ARIAS AND CAROLEE PURCELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6796-06S. Filed November 6, 2007.
Hector F. Arias and Carolee Purcell, pro sese.
Neal O. Abreu, for respondent.
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect when the petition was filed. Pursuant to
section 7463(b), the decision to be entered is not reviewable by
any other court, and this opinion shall not be treated as
precedent for any other case. Unless otherwise indicated,
subsequent section references are to the Internal Revenue Code in
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