Michael R. and Shelley F. Fawcett - Page 2















                            T.C. Summary Opinion 2001-65                              


                               UNITED STATES TAX COURT                                


                  MICHAEL R. AND SHELLEY F. FAWCETT, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 15851-99S.                     Filed May 2, 2001.           

               Michael R. and Shelley F. Fawcett, pro sese.                           
               Julie L. Payne, for respondent.                                        

          GOLDBERG, 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.  The decision to be              
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.  Unless otherwise indicated,              
          subsequent section references are to the Internal Revenue Code as           
          amended and in effect for the year at issue.                                
               Respondent determined a deficiency in petitioners’ Federal             
          income tax in the amount of $5,526 for the 1995 tax year.                   





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