T.C. Summary Opinion 2003-138
UNITED STATES TAX COURT
ALAN C. AND ESTHER R. SCHWEMMER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9461-02S. Filed September 30, 2003.
Alan C. Schwemmer and Esther R. Schwemmer, pro sese.
Huong T. Duong, for respondent.
PAJAK, Special Trial Judge: This matter is before the Court
on respondent’s motion for summary judgment, filed pursuant to
Rule 121(a). 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. The decision to be entered is not
reviewable by any other court, and this opinion should not be
cited as authority. Unless otherwise indicated, all section
references are to the Internal Revenue Code, as amended, and all
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