T.C. Summary Opinion 2001-82
UNITED STATES TAX COURT
MARSHALL STEWART GARDNER AND NANCY B. GARDNER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6563-00S. Filed June 11, 2001.
Marshall Stewart Gardner and Nancy B. Gardner, pro sese.
Jack T. Anagnostis, 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 at issue. 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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