T.C. Summary Opinion 2003-121                             
                               UNITED STATES TAX COURT                                
                         BRUCE EDWARD KENNEDY, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 10013-01S.           Filed August 27, 2003.                 
               Bruce Edward Kennedy, pro se.                                          
               Richard J. Hassebrock, 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            
          is not reviewable by any other court, and this opinion should not           
               1    Unless otherwise indicated, subsequent section                    
          references are to the Internal Revenue Code in effect for the               
          year at issue.  Rule references are to the Tax Court Rules of               
          Practice and Procedure.                                                     
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