T.C. Summary Opinion 2001-49
UNITED STATES TAX COURT
DON E. KRAMER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12198-99S. Filed April 4, 2001.
George Edward Marifian and Mary E. Lopinot, for petitioner.
James A. Kutten, 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 in
effect for the year in issue.
Respondent determined a deficiency in petitioner’s Federal
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