T.C. Summary Opinion 2004-170
UNITED STATES TAX COURT
JAMES P. ELLIS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11098-03S. Filed December 20, 2004.
James P. Ellis, pro se.
Cynthia J. Olson, for respondent.
DEAN, 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, 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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