T.C. Summary Opinion 2003-149
UNITED STATES TAX COURT
JANIE M. DIXON AND JOSEPH DIXON, JR., Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3356-03S. Filed October 10, 2003.
Michael S. McNair, for petitioners.
Alan Friday, for respondent.
WHERRY, Judge: This case is before the Court on
respondent’s motion for partial summary judgment under Rule 121.1
The petition was filed pursuant to the provisions of section
7463. The decision to be entered is not reviewable by any other
court, and this opinion should not be cited as authority. The
instant proceeding arises from a petition for judicial review
1 Unless otherwise indicated, section references are to the
Internal Revenue Code of 1986, as amended, and Rule references
are to the Tax Court Rules of Practice and Procedure.
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