T.C. Summary Opinion 2003-130
UNITED STATES TAX COURT
THOMAS E. TRUSKOWSKY AND SUSAN L. TRUSKOWSKY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14066-01S. Filed September 15, 2003.
Harry D. Shapiro and Christopher J. Pippett, for
petitioners.
Innessa Glazman and Warren P. Simonsen, for respondent.
DEAN, Special Trial Judge: This case was heard under the
provisions of section 7463 of the Internal Revenue Code as in
effect at the time the petition was filed. Unless otherwise
indicated, all other section references are to the Internal
Revenue Code in effect for the years at issue. The decision to
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