T.C. Summary Opinion 2004-93
UNITED STATES TAX COURT
MARCELO E. FERRADA AND GLORIA D. FERRADA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3084-03S. Filed July 19, 2004.
Marcelo E. and Gloria D. Ferrada, pro sese.
W. Lance Stodghill, 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 year in issue. The decision to be
entered is not reviewable by any other court, and this opinion
should not be cited as authority.
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