T.C. Summary Opinion 2006-82
UNITED STATES TAX COURT
MARK E. PICOU, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 10879-05S, 24363-05S. Filed May 22, 2006.
Mark E. Picou, pro se.
Michael W. Bitner, for respondent.
ARMEN, Special Trial Judge: These consolidated cases were
heard pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect when the petitions were filed.1 The
decisions to be entered are not reviewable by any other court,
and this opinion should not be cited as authority.
1 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002
and 2003, the taxable years in issue. All monetary amounts are
rounded.
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