Daniel J. and Joyce A. Roderick - Page 2

                             T.C. Summary Opinion 2007-6                              


                               UNITED STATES TAX COURT                                


                   DANIEL J. AND JOYCE A. RODERICK, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 23130-05S.             Filed January 10, 2007.              


               Daniel J. and Joyce A. Roderick, pro se.                               
               James H. Brunson, for respondent.                                      


               WELLS, Judge:  This case was heard pursuant to the                     
          provisions of section 7463 in effect at the time 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.  All              
          section references are to the Internal Revenue Code, as amended,            
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              





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