Ali and Arlene Mohammadpour - Page 2

                            T.C. Summary Opinion 2007-163                             

                               UNITED STATES TAX COURT                                

                     ALI AND ARLENE MOHAMMADPOUR, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3787-06S.             Filed September 12, 2007.             

               Ali Mohammadpour, pro se.                                              
               Emly B. Berndt, for respondent.                                        

               JACOBS, 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.1  Pursuant to section                   
          7463(b), the decision to be entered is not reviewable by any                

               1Unless otherwise indicated, subsequent 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.                                                              

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Last modified: November 10, 2007