D. Lloyd and Betty Thomas - Page 2
















                            T.C. Summary Opinion 2001-136                             


                               UNITED STATES TAX COURT                                


                      D. LLOYD AND BETTY THOMAS, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3672-00S.                Filed September 5, 2001.           

               D. Lloyd and Betty Thomas, pro sese.                                   
               Elizabeth Owen, for respondent.                                        

               ARMEN, Special Trial Judge: This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time that the petition was filed.1  The decision to           
          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           



               1 All subsequent section references are to the Internal                
          Revenue Code in effect for 1997, the taxable year in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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