Leo and Shawn M. Stephens - Page 2















                            T.C. Summary Opinion 2008-18                              


                               UNITED STATES TAX COURT                                


                      LEO AND SHAWN M. STEPHENS, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 9171-06S.            Filed February 25, 2008.               


               Reggie L. Wegner, for petitioners.                                     
               Milan H. Kim and David Conrad, for respondent.                         

               FOLEY, 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,            


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code of 1986, as amended and in effect for             
          the years in issue.                                                         







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