T.C. Summary Opinion 2006-49
UNITED STATES TAX COURT
MICHAEL AND PENNY RHODES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17280-03S. Filed April 11, 2006.
Douglas E. Johnston, for petitioners.
Timothy A. Lohrstorfer, 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 years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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