T.C. Summary Opinion 2006-52
UNITED STATES TAX COURT
ESTHER A. D’AVILAR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10097-04S. Filed April 17, 2006.
Esther A. D’Avilar, pro se.
Michelle L. Maniscalco, for respondent.
CARLUZZO, Special Trial Judge: This case for the
redetermination of a deficiency 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 2000. Rule references are to the Tax Court Rules of
Practice and Procedure. The decision to be entered is not
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