James Albert and Beverly Alderman - Page 2

                            T.C. Summary Opinion 2004-74                              


                               UNITED STATES TAX COURT                                


                  JAMES ALBERT AND BEVERLY ALDERMAN, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 18818-02S.             Filed May 26, 2004.                  

               James Albert and Beverly Alderman, pro sese.                           
               Linda J. Wise, for respondent.                                         


               WHERRY, Judge:  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.1  The decision to be entered            
          is not reviewable by any other court, and this opinion should not           
          be cited as authority.                                                      


               1 Unless otherwise indicated, subsequent section references            
          are to the Internal Revenue Code in effect for the year in issue,           
          and Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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