T.C. Summary Opinion 2006-51
UNITED STATES TAX COURT
JOHN BOTHE AND BARBARA BOTHE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6737-04S. Filed April 12, 2006.
Stanley Pressment, for petitioners.
Michelle L. Maniscalco, for respondent.
CARLUZZO, 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. Unless otherwise
indicated, subsequent section references are to the Internal
Revenue Code in effect for 1999. Rule references are to the Tax
Court Rules of Practice and Procedure. The decision to be
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