T.C. Summary Opinion 2002-42
UNITED STATES TAX COURT
JAMES J. COYLE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
REGAL MOBILE HOME SALES, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 12012-99S, 12061-99S. Filed April 22, 2002.
William James Kelly, for petitioners.
Randall B. Pooler, for respondent.
PANUTHOS, Chief Special Trial Judge: These cases were heard
pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect at the time the petitions were filed. The
decisions to be entered are not reviewable by any other court,
and this opinion should not be cited as authority. Unless
otherwise indicated, subsequent section references are to the
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