T.C. Summary Opinion 2005-174
UNITED STATES TAX COURT
RICHARD ALAN CRONK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4544-04S. Filed November 29, 2005.
Richard Alan Cronk, pro se.
Aimee R. Lobo-Berg, 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
1Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the year at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure. The Court decides this case without regard to the
burden of proof, except that, with respect to the addition to tax
and the penalty, the burden of proof is on respondent. Sec.
7491.
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