T.C. Summary Opinion 2004-130
UNITED STATES TAX COURT
DAVID A. BROWN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 11482-02S. Filed September 20, 2004.
David A. Brown, pro se.
Marc L. Caine, for respondent.
WOLFE, 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. Unless otherwise
indicated, all subsequent section references are to the Internal
* This report is a supplement to Brown v. Commissioner,
T.C. Summary Opinion 2004-45, filed Apr. 6, 2004, hereafter
referred to as the “previous opinion”.
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