T.C. Summary Opinion 2006-24
UNITED STATES TAX COURT
JAMES CASTAGNETTA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22132-03S. Filed February 13, 2006.
James Castagnetta, pro se.
Frank J. Jackson, 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 the year in issue. Rule references
are to the Tax Court Rules of Practice and Procedure. The
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