T.C. Summary Opinion 2005-91
UNITED STATES TAX COURT
JAMES A. AND NANCY B. WIESE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16545-04S. Filed July 19, 2005.
James A. Wiese and Nancy B. Wiese, pro sese.
Albert B. Kerkhove and J. Anthony Hoefer, 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 that the petition was filed.1 The decision to
1 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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