Thomas Patrick and Christine E. Dawson - Page 2















                            T.C. Summary Opinion 2008-17                              


                               UNITED STATES TAX COURT                                


               THOMAS PATRICK AND CHRISTINE E. DAWSON, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 20323-06S.            Filed February 20, 2008.              


               Thomas Patrick and Christine E. Dawson, pro sese.                      
               Harry J. Negro, for respondent.                                        


               RUWE, Judge:  This case was heard pursuant to the provisions           
          of section 74631 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.                       



               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code (Code) in effect for the year in issue.           





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