James L. and Patricia R. Williams - Page 2















                            T.C. Summary Opinion 2007-102                             


                               UNITED STATES TAX COURT                                


                  JAMES L. AND PATRICIA R. WILLIAMS, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8323-06S.             Filed June 20, 2007.                  

               James L. and Patricia R. Williams, pro sese.                           
               Lynn M. Curry, for respondent.                                         


               PANUTHOS, Chief Special Trial Judge:  This case was heard              
          pursuant to the provisions of section 7463 of the Internal                  
          Revenue Code in effect when 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           








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