Royal and Shelly Spence Wiley - Page 2
















                            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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