T.C. Summary Opinion 2003-43
UNITED STATES TAX COURT
DENNIS W. FARLEY, JR. AND JANICE J. FARLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7920-01S. Filed April 22, 2003.
Dennis W. Farley, Jr. and Janice J. Farley, pro se.
Dennis R. Onnen, 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
years at issue. Rule references are to the Tax Court Rules of
Practice and Procedure.
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