Huon Pen - Page 2

                            T.C. Summary Opinion 2006-33                              

                               UNITED STATES TAX COURT                                

                               HUON PEN, Petitioner v.                                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17718-02S.           Filed February 22, 2006.               

               Huon Pen, pro se.                                                      
               Nhi T. Luu-Sanders, 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 in this case 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 years at                 
          issue.  Sec. 7491 in some instances shifts the burden of proof to           
          the Commissioner.  That section is not applicable in this case              
          because the issues are legal and not factual.                               

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