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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