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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