Robert and Cheryl McKeown - Page 2

                            T.C. Summary Opinion 2007-95                              

                               UNITED STATES TAX COURT                                

                      ROBERT AND CHERYL MCKEOWN, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 21967-05S.            Filed June 13, 2007.                  

               Robert and Cheryl McKeown, pro sese.                                   
               David L. Zoss, for respondent.                                         

               KROUPA, Judge:  This case was heard pursuant to the                    
          provisions of section 74631 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                

               1All section references are to the Internal Revenue Code in            
          effect for 2003, and all Rule references are to the Tax Court               
          Rules of Practice and Procedure, unless otherwise indicated.                

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