T.C. Summary Opinion 2004-54
UNITED STATES TAX COURT
SAMUEL S. LOWE III AND NANCY S. LOWE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2766-03S. Filed May 11, 2004.
Samuel S. Lowe III and Nancy S. Lowe, pro sese.
Horace Crump, for respondent.
WHERRY, 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.1 The decision to be entered
is not reviewable by any other court, and this opinion should not
be cited as authority.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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