David M. and Phyllis E. Brown - Page 2

                            T.C. Summary Opinion 2007-166                             

                               UNITED STATES TAX COURT                                

                    DAVID M. AND PHYLLIS E. BROWN, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6412-04S.             Filed September 24, 2007.             

               David M. and Phyllis E. Brown, pro sese.                               
               Randall L. Preheim, for respondent.                                    

               VASQUEZ, Judge:  This case was heard pursuant to the                   
          provisions of section 7463 of the Internal Revenue Code in effect           
          when the petition was filed.1  Pursuant to section 7463(b), the             
          decision to be entered is not reviewable by any other court, and            

               1  Unless otherwise indicated, all Rule references are to              
          the Tax Court Rules of Practice and Procedure, and all section              
          references are to the Internal Revenue Code in effect for the               
          year in issue.                                                              

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