T.C. Summary Opinion 2002-123
UNITED STATES TAX COURT
ROBERT A. WODARCZYK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8845-01S. Filed September 30, 2002.
Tommy E. Swate, for petitioner.
Bruce M. Wilpon, for respondent.
COUVILLION, Special Trial Judge: Respondent filed a motion
for summary judgment under Rule 121. The petition was filed
pursuant to section 7463.1 The decision to be entered is not
reviewable by any other court, and this opinion should not be
cited as authority. The case arises from a petition for judicial
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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