T.C. Summary Opinion 2004-142
UNITED STATES TAX COURT
SHARON J. FIX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12958-99S. Filed October 14, 2004.
Sharon J. Fix, pro se.
J. Robert Cuatto, for respondent.
WOLFE, Special Trial Judge: This matter is before the Court
on petitioner’s Motion for Leave to File Motion to Vacate Out of
Time (embodying Motion to Vacate) (Motion), filed on January 21,
2004. It was heard pursuant to the provisions of section 7463 of
the Internal Revenue Code. All section references are to the
Internal Revenue Code in effect at relevant times, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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