T.C. Summary Opinion 2004-24
UNITED STATES TAX COURT
GIL G. AND PATROCENIA C. SANTILLA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2485-03S. Filed March 9, 2004.
Gil G. Santilla, pro se.
Donna L. Pahl, for respondent.
GOLDBERG, 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. The decision to be
entered is not reviewable by any other court, and this opinion
should not be cited as authority. Unless otherwise indicated,
subsequent section references are to the Internal Revenue Code in
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