T.C. Summary Opinion 2006-153
UNITED STATES TAX COURT
REGINA FELTON, PC, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14333-05S. Filed September 18, 2006.
Regina Felton (an officer), for petitioner.
Diana Hinton, for respondent.
ARMEN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7463 of the Internal Revenue Code in
effect when the petition was filed.1 The decision to be entered
1 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2001
and 2002, the taxable years in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure.
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