T.C. Summary Opinion 2004-16
UNITED STATES TAX COURT
SANDRA BROWDA, Petitioner, AND DAVID BROWDA, Intervenor v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17710-02S. Filed February 12, 2004.
Sandra Browda, pro se.
David Browda, pro se.
Michael E. Melone, for respondent.
ARMEN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7463 of the Internal Revenue Code in
effect at the time that the petition was filed.1 The decision to
1 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for the
taxable years in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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