T.C. Summary Opinion 2004-32
UNITED STATES TAX COURT
HAROLD AND DOREEN SILK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16009-02S. Filed March 18, 2004.
Shawn A. Silk, for petitioners.
Frank N. Panza, 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
be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
1 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for the
taxable years in issue. All Rule references are to the Tax Court
Rules of Practice and Procedure.
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