Richard and Arline Muller - Page 2

                            T.C. Summary Opinion 2007-207                             

                               UNITED STATES TAX COURT                                

                      RICHARD AND ARLINE MULLER, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 21941-05S.            Filed December 10, 2007.              

               Richard Muller and Arline Muller, pro sese.                            
               Kristina L. Rico, for respondent.                                      

               CARLUZZO, Special Trial Judge:  This case was heard                    
          pursuant to the provisions of section 7463.1  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.                                                         

               1  Unless otherwise indicated, section references are to the           
          Internal Revenue Code of 1986, as amended, in effect for the                
          relevant period.                                                            

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