T.C. Memo. 2003-91
UNITED STATES TAX COURT
MITCHELL S. WIEST, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 256-00. Filed March 27, 2003.
Mitchell S. Wiest, pro se.
Martha J. Weber, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: This case is before the Court on petitioner’s
petition to review respondent’s denial of relief under section
60151 with respect to petitioner’s 1994 taxable year. We hold
1 Unless otherwise noted, all section references are to the
Internal Revenue Code as amended, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
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