William E. and Karen L. Kivett - Page 2

                            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           

Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011