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 (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 Next
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