T.C. Summary Opinion 2004-46
UNITED STATES TAX COURT
NEAL N. AND RUBY W. VIAR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13785-02S. Filed April 12, 2004.
Neal N. and Ruby W. Viar, pro se.
Dustin M. Starbuck, 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
years at issue. Rule references are to the Tax Court Rules of
Practice and Procedure.
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