Chad W. and Aliza Kold-Warren - Page 2

                            T.C. Summary Opinion 2007-197                             

                               UNITED STATES TAX COURT                                

                    CHAD W. AND ALIZA KOLD-WARREN, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 24445-05S.            Filed November 21, 2007.              

               Chad W. and Aliza Kold-Warren, pro se.                                 
               Michael S. Hensley, for respondent.                                    

               WHALEN, Judge:  This case was heard pursuant to the                    
          provisions of section 7463 of the Internal Revenue Code in effect           
          when the petition was filed.  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, unless otherwise indicated.  Pursuant to section                 
          7463(b), the decision to be entered is not reviewable by any                

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