T.C. Summary Opinion 2002-40
UNITED STATES TAX COURT
BARRY JOHN AND DEBORAH LEE HOUSTON MANGELS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9628-00S. Filed April 15, 2002.
Barry John and Deborah Lee Houston Mangels, pro se.
Monica J. Miller, for respondent.
PANUTHOS, Chief 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.
Unless otherwise indicated, subsequent section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
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