T.C. Summary Opinion 2003-29
UNITED STATES TAX COURT
IRWIN AND JEANNINE RADNITZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2162-01S. Filed March 26, 2003.
Irwin and Jeannine Radnitz, pro se.
Jonathan H. Sloat, 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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