T.C. Summary Opinion 2001-35
UNITED STATES TAX COURT
EDWARD M. FIELDS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17174-98S. Filed March 20, 2001.
James Charles Frooman, for petitioner.
Gary R. Shuler, Jr., for respondent.
CARLUZZO, 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 1995. Rule references are to the Tax
Court Rules of Practice and Procedure. The decision to be
entered is not reviewable by any other court, and this opinion
should not be cited as authority.
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