T.C. Summary Opinion 2003-162
UNITED STATES TAX COURT
MICHAEL ROBERT COTTRELL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 127-03S. Filed November 18, 2003.
Michael Robert Cottrell, 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
1
Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the year at issue,
and Rule references are to the Tax Court Rules of Practice and
Procedure.
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