T.C. Summary Opinion 2006-108
UNITED STATES TAX COURT
MICHAEL E. AND LAURA A. TAYLOR, Petitioners v. COMMISSIONER OF
INTERNAL REVENUE, Respondent
Docket No. 12423-04S. Filed July 17, 2006.
Ronald W. Blasi and Michael L.P. Jacobs (specially
recognized), for petitioners.
Brenda M. Fitzgerald, for respondent.
POWELL, Special Trial Judge: This case was heard pursuant
to section 74631 of the Internal Revenue Code in effect at the
time the petition was filed. The decision to be entered is not
1 Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year in issue.
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