Wickie B. Whalen - Page 2

                            T.C. Summary Opinion 2005-45                              


                               UNITED STATES TAX COURT                                


                           WICKIE B. WHALEN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 22269-03S.           Filed April 18, 2005.                  

               Wickie B. Whalen, pro se.                                              
               Lauren B. Epstein and Willie Fortenberry, Jr., for                     
          respondent.                                                                 


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time that the petition was filed.  Unless otherwise           
          indicated, all subsequent section references are to the Internal            
          Revenue Code in effect for the year in issue.  The decision to be           
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           






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