T.C. Summary Opinion 2007-60
UNITED STATES TAX COURT
MANUEL AYALA, JR., AND CAROL A. AYALA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5395-06S. Filed April 23, 2007.
Manuel Ayala, Jr., pro se.
Derek W. Kaczmarek, for respondent.
ARMEN, Special Trial Judge: This case was heard pursuant to
the provisions of section 7463 of the Internal Revenue Code in
effect when the petition was filed.1 Pursuant to section
7463(b), the decision to be entered is not reviewable by any
1 Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for the
taxable years in issue.
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Last modified: November 10, 2007