T.C. Summary Opinion 2004-147
UNITED STATES TAX COURT
WILLIAM C. EBERHARDT, JR. AND SUSAN A. EBERHARDT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1918-03S. Filed October 21, 2004.
William C. Eberhardt, Jr. and Susan A. Eberhardt, pro sese.
Kevin W. Coy, for respondent.
DEAN, Special Trial Judge: This case was heard pursuant to
the provisions of sections 6330(d) and 7463 of the Internal
Revenue Code in effect at the time that the petition was filed.
Unless otherwise indicated, subsequent section references are to
the Internal Revenue Code in effect at all relevant times, and
all Rule references are to the Tax Court Rules of Practice and
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