Sandrea Maryann and Robert Maynard Woehl - Page 2















                            T.C. Summary Opinion 2007-87                              


                               UNITED STATES TAX COURT                                


              SANDREA MARYANN AND ROBERT MAYNARD WOEHL, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 2735-05S.              Filed May 29, 2007.                  



               Glen L. Moss, for petitioners.                                         
               Stephanie M. Profitt, for respondent.                                  


               DEAN, 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.  Unless otherwise indicated,            
          all section references are to the Internal Revenue Code, and all            
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  Pursuant to section 7463(b), the decision to be                 








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