T.C. Summary Opinion 2002-33
UNITED STATES TAX COURT
WALLACE F. AND MI-JA H. SMITH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10017-00S. Filed April 3, 2002.
Wallace F. and Mi-Ja H. Smith, pro se.
Daniel J. Parent, for respondent.
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7463 of the Internal Revenue Code in effect
at the time 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 Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year at issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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