S.W. DePasture - Page 2
















                            T.C. Summary Opinion 2003-27                              


                               UNITED STATES TAX COURT                                


                           S.W. DEPASTURE, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 615-00S.              Filed March 26, 2003.                 


               L. Andrew Smith, for petitioner.                                       
               Brandi B. Darwin, for respondent.                                      


               CARLUZZO, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7463 of the Internal Revenue Code in           
          effect at the time the petition was filed.  Except for section              
          60151 and unless otherwise indicated, subsequent section                    


               1 Sec. 6015 was added to the Internal Revenue Code by the              
          Internal Revenue Service Restructuring and Reform Act of 1998,              
          Pub. L. 105-206, sec. 3201(a), 112 Stat. 734, effective for any             
          liability for tax arising after July 22, 1998, and any liability            
          for tax arising on or before July 22, 1998, but remaining unpaid            
          as of July 22, 1998.                                                        




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