Graeme C. Revell and Brenda S. Revell - Page 1

                                 T.C. Memo. 2007-37                                   

                               UNITED STATES TAX COURT                                

                GRAEME C. REVELL AND BRENDA S. REVELL, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1636-04.           Filed February 20, 2007.                 

               Warren N. Nemiroff, for petitioners.                                   
               Jack H. Klinghoffer, for respondent.                                   

                                 MEMORANDUM OPINION                                   

               LARO, Judge:  On March 20, 2006, the parties filed with the            
          Court a stipulation of settled issues (settlement stipulation)              
          that included this case and five other cases that had been                  
          consolidated therewith.  Respondent now moves the Court to enter            
          a decision in this case that is consistent with the settlement              
          stipulation and has attached to his motion the computations                 

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