T.C. Memo. 2000-60
UNITED STATES TAX COURT
ANTONIO & LUZVIMINDA PUNGOT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20036–97. Filed February 24, 2000.
Richard J. Sapinski, for petitioners.
Robert F. Saal and Guy G. Lavignera, for respondent.
MEMORANDUM OPINION
FAY, Judge: Respondent determined deficiencies of $10,756
and $10,974 in petitioners’ 1994 and 1995 Federal income taxes,
respectively. After concessions, the issue for decision is
whether section 469(c)(7)(D)(ii)1 is unconstitutional.
1All section references are to the Internal Revenue Code in
effect for 1994 and 1995, and all Rule references are to the Tax
Court Rules of Practice and Procedure, unless otherwise noted.
Page: 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011