T.C. Summary Opinion 2004-160
UNITED STATES TAX COURT
MARIA ANTOINETTE WALTON MITCHELL AND LARRY G. MITCHELL,
Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1751-03S. Filed November 23, 2004.
Maria Antoinette Walton Mitchell and Larry G. Mitchell, pro
sese.
Roger P. Law and Ron S. Chun, for respondent.
ARMEN, 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.1 The decision to
1 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2000,
the taxable year in issue. All monetary amounts are rounded to
the nearest dollar.
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