T.C. Summary Opinion 2004-176
UNITED STATES TAX COURT
VICKI JO JAMES, Petitioner
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9856-03S. Filed December 28, 2004.
Steve Allen Claus, for petitioner.
Abbey B. Garber and Adam L. Flick (specially recognized),
for respondent.
CARLUZZO, 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.1 The decision to be
1 Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect at the time the
petition was filed.
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