T.C. Summary Opinion 2004-8
UNITED STATES TAX COURT
WILLIAM J. CUTTS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
AMERICAN TANK & VESSEL, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 10471-01S, 10472-01S. Filed January 29, 2004.
Irvin Grodsky, for petitioners.
Linda J. Wise, for respondent.
BEGHE, Judge: These consolidated cases were heard pursuant
to section 7463 of the Internal Revenue Code in effect when the
petitions were filed.1 The decisions to be entered are
1Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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