T.C. Summary Opinion 2004-168
UNITED STATES TAX COURT
EVANS A. MBACHU, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2914-04S. Filed December 7, 2004.
Evans A. Mbachu, pro se.
John W. Sheffield III, for respondent.
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7463 of the Internal Revenue Code in effect
at the time the petition was filed.1 The decision to be entered
1 Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year at issue. Rule references are to the Tax Court Rules of
Practice and Procedure.
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