T.C. Summary Opinion 2005-118
UNITED STATES TAX COURT
N. THOMAS RYAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13239-02S. Filed August 10, 2005.
N. Thomas Ryan, pro se.
Francis Mucciolo and Michael D. Zima, for respondent.
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect when the petition was filed. The decision
to be entered is not reviewable by any other court, and this
opinion should not be cited as authority. Unless otherwise
indicated, all subsequent section references are to the Internal
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