James M. and Ruth J. Riley - Page 2

                            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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