T.C. Summary Opinion 2006-114
UNITED STATES TAX COURT
WILLIAM E. AND KAREN L. KIVETT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15448-04S. Filed July 18, 2006.
Karen L. Kivett, pro se.
Robert V. Boeshaar, for respondent.
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7463 in effect when the petition was filed.1
1Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the year at issue.
Under sec. 7491, the burden of proof shifts to the Commissioner
if the taxpayer complies with the requirements to substantiate
any item and maintains records and cooperates with reasonable
requests for witnesses, information, documents, meetings, and
interviews. The facts of this case do not warrant a shift in the
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