Brian E. & Marcie L. Mallin - Page 2















                            T.C. Summary Opinion 2008-13                              


                               UNITED STATES TAX COURT                                


                     BRIAN E. & MARCIE L. MALLIN, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 2370-06S.             Filed February 11, 2008.              


               Brian E. Mallin and Marcie L. Mallin, pro sese.                        
               Tamara L. Kotzker, for respondent.                                     


               ARMEN, 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.1  Pursuant to section                   
          7463(b), the decision to be entered is not reviewable by any                


               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for the               
          taxable years in issue, and all Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      





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