Scott Owen Schubert & Amy K. Moore - Page 2















                            T.C. Summary Opinion 2008-24                              


                               UNITED STATES TAX COURT                                


                SCOTT OWEN SCHUBERT AND AMY K. MOORE, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 22477-06S.            Filed March 5, 2008.                  


               Scott Owen Schubert and Amy K. Moore, pro sese.                        
               Margaret A. Martin, for respondent.                                    


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code (IRC)           
          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 IRC in effect for the year in                 







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