Douglas W. and Gail Caple - Page 2















                            T.C. Summary Opinion 2007-206                             


                               UNITED STATES TAX COURT                                


                      DOUGLAS W. AND GAIL CAPLE, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 22697-04S.            Filed December 10, 2007.              


               Douglas W. and Gail Caple, pro sese.                                   
               Mark D. Peterson and Mark Miller, for respondent.                      
                                                                                     

               GOLDBERG, 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.  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.                        







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