T.C. Summary Opinion 2006-18
UNITED STATES TAX COURT
TONY G. AND ROBERTA A. MONTGOMERY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3564-04S. Filed February 6, 2006.
Tony G. Montgomery, pro se.
Michael W. Bitner, for respondent.
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7463 in effect when the petition was filed.1
The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
1Unless otherwise indicated, section references hereafter
are to the Internal Revenue Code in effect for the year at issue.
This case is decided without regard to the burden of proof. In
some instances, sec. 7491 shifts the burden of proof to
respondent. Since this case involves only a question of law,
sec. 7491 is not applicable here.
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