Raymond and Cynthia Daley Zakrzewski - Page 2















                            T.C. Summary Opinion 2007-97                              


                               UNITED STATES TAX COURT                                


                RAYMOND AND CYNTHIA DALEY ZAKRZEWSKI, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 9623-05S.              Filed June 18, 2007.                 


               Raymond and Cynthia Daley Zakrzewski, pro sese.                        

               Julie A. Jebe, for respondent.                                         

               GOLDBERG, Special Trial 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           







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