T.C. Summary Opinion 2001-158
UNITED STATES TAX COURT
MAJID NAEMI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8339-00S. Filed September 26, 2001.
Majid Naemi, pro se.
Michelle A. Yates, 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.1 The decision to be
1All 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,
unless otherwise indicated.
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