T.C. Summary Opinion 2004-139
UNITED STATES TAX COURT
GARY W. AND DARLENE E. WHITE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 414-03S. Filed October 12, 2004.
Gary W. and Darlene E. White, pro sese.
Robert S. Scarbrough, 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 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 1999
and 2000, the taxable years in issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
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