John C. and Joan F. Stukes - Page 2














                            T.C. Summary Opinion 2007-65                              


                               UNITED STATES TAX COURT                                


                     JOHN C. AND JOAN F. STUKES, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16648-05S.             Filed April 26, 2007.                

               John C. Stukes, pro se.                                                
               David B. Mora, for respondent.                                         


               JACOBS, Judge:  This case was heard pursuant to the                    
          provisions of section 7463 of the Internal Revenue Code in effect           
          at the time the petition was filed.  Pursuant to section 7463(b),           
          the decision to be entered is not reviewable by any other court,            
          and this opinion shall not be treated as precedent for any other            
          case.  Unless otherwise indicated, subsequent section references            
          are to the Internal Revenue Code in effect for the year in issue,           








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