T.C. Summary Opinion 2003-106
UNITED STATES TAX COURT
WILLIAM T. ELLIOTT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12262-01S. Filed July 25, 2003.
Tommy E. Swate, for petitioner.
Daniel N. Price, for respondent.
DEAN, 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. Unless otherwise
indicated, subsequent section references are to the Internal
Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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