T.C. Summary Opinion 2007-26
UNITED STATES TAX COURT
JAMES M. AND RUTH J. RILEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23681-05S. Filed February 26, 2007.
James M. and Ruth J. Riley, pro sese.
Marion K. Mortensen, for respondent.
DAWSON, Judge: This case was heard pursuant to section 7463
of the Internal Revenue Code in effect when the petition was
filed.1 The decision to be entered is not reviewable by any
other court, and this opinion should not be cited as authority.
1Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the years at
issue, and Rule references are to the Tax Court Rules of Practice
and Procedure.
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