Richard Allan and Corinne Lucille Balser - Page 2














          T.C. Summary Opinion 2007-123                                               


                               UNITED STATES TAX COURT                                


              RICHARD ALLAN AND CORINNE LUCILLE BALSER, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 19611-05S.            Filed July 19, 2007.                  

               John S. Kutscher, for petitioners.                                     
               Catherine L. Campbell, for respondent.                                 


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time the petition was filed.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code of 1986 as amended (Code).  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.                                                         







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