T.C. Summary Opinion 2006-176 UNITED STATES TAX COURT PATRICK M. SHANNON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9574-05S. Filed October 25, 2006. Patrick M. Shannon, pro se. Lisa K. Hunter, for respondent. CHIECHI, Judge: This case is before the Court on respon- dent’s motion for summary judgment (respondent’s motion)1 and was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time that the petition was filed.2 1Although the Court ordered petitioner to file a response to respondent’s motion, petitioner failed to do so. 2All section references are to the Internal Revenue Code in (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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