T.C. Summary Opinion 2004-113
UNITED STATES TAX COURT
WILLIAM G. APPLEGATE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
LUCY S. WANG, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 19676-02S, 19692-02S. Filed August 24, 2004.
William G. Applegate, pro se in docket No. 19676-02S.
Lucy S. Wang, pro se in docket No. 19692-02S.
Timothy S. Sinnott, for respondent.
DEAN, Special Trial Judge: These consolidated cases were
heard pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect at the time that the petitions were filed.
Unless otherwise indicated, subsequent section references are to
the Internal Revenue Code in effect for the year in issue, and
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