T.C. Summary Opinion 2002-116
UNITED STATES TAX COURT
ROYAL AND SHELLY SPENCE WILEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11332-01S. Filed September 4, 2002.
Royal and Shelly Spence Wiley, pro se.
Douglas S. Polsky, 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
years at issue. All Rule references are to the Tax Court Rules
of Practice and Procedure.
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