T.C. Summary Opinion 2006-156
UNITED STATES TAX COURT
SANTIAGO L. GARCIA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10950-05S. Filed September 25, 2006.
Santiago L. Garcia, pro se.
Robert W. Dillard, for respondent.
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7463 in effect when the petition was filed.
The decision to be entered in this case is not reviewable by any
other Court, and this opinion should not be cited as authority.1
1Unless otherwise indicated, section references hereafter
are to the Internal Revenue Code in effect for the year at issue.
Sec. 7491 in certain instances shifts the burden of proof to the
Commissioner where the taxpayer introduces credible evidence with
respect to any factual issue relevant to ascertaining the
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