Dennis J. Lawless - Page 2

                            T.C. Summary Opinion 2001-178                             

                               UNITED STATES TAX COURT                                

                          DENNIS J. LAWLESS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1926-00S.                Filed November 28, 2001.           

               Dennis J. Lawless, pro se.                                             
               John E. Glover, for respondent.                                        

               THORNTON, Judge:  This case was heard pursuant to the                  
          provisions of section 7463 of the Internal Revenue Code in effect           
          when 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, all subsequent             
          section references are to the Internal Revenue Code in effect for           
          the year in issue, and all Rule references are to the Tax Court             
          Rules of Practice and Procedure.                                            

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