Anthony Edward and S.F. O'Connor - Page 2

                            T.C. Summary Opinion 2007-32                              

                               UNITED STATES TAX COURT                                

                  ANTHONY EDWARD AND S.F. O’CONNOR, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8378-06S.             Filed March 5, 2007.                  

               Anthony Edward and S.F. O’Connor, pro sese.                            
               Jeffrey S. Luechtefeld, for respondent.                                

               PANUTHOS, Chief Special Trial Judge:  This case was heard              
          pursuant to the provisions of sections 6330(d) and 7463 of the              
          Internal Revenue Code in effect when the petition was filed.  The           
          decision to be entered is not reviewable by any other court, and            
          this opinion should not be cited as authority.  Unless otherwise            
          indicated, all subsequent section references are to the Internal            
          Revenue Code in effect at relevant times.                                   

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