T.C. Summary Opinion 2005-1
UNITED STATES TAX COURT
JOHN A. WALZ, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17415-03S. Filed January 3, 2005.
Charles Herbert Magnuson, for petitioner.
Valerie L. Makarewicz, for respondent.
PAJAK, 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. The decision to be
entered is not reviewable by any other court, and this opinion
should not be cited as authority. Unless otherwise indicated,
subsequent section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
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