T.C. Summary Opinion 2004-59
UNITED STATES TAX COURT
RALPH D. AND BRENDA KONCHAR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5388-01S. Filed May 13, 2004.
Ralph D. and Brenda Konchar, pro sese.
Jason W. Anderson and Thomas Yang, 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 the petition was filed. Unless otherwise
indicated, subsequent section references are to the Internal
Revenue Code in effect for the years at 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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