T.C. Summary Opinion 2001-48
UNITED STATES TAX COURT
THEODORE B. BARE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3271-98S. Filed April 4, 2001.
Bradley S. Shannon, Amanda Skiles, and Jesse Smith, for
petitioner.
Shirley M. Francis, for respondent.
DEAN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7463 of the Internal Revenue Code in
effect at the time the petition was filed. Unless otherwise
indicated, subsequent section references are to the Internal
Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court of Practice and Procedure. The
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