T.C. Summary Opinion 2002-106
UNITED STATES TAX COURT
CHARLES J. AND HYLA J. PORTALUPPI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5558-00S. Filed August 12, 2002.
Charles J. and Hyla J. Portaluppi, pro se.
William J. Gregg, 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. The
decision to be entered is not reviewable by any other court, and
this opinion should not be cited as authority. Unless otherwise
indicated, subsequent section references are to the Internal
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