T.C. Summary Opinion 2007-4
UNITED STATES TAX COURT
JOHNNY AYRES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12569-05S. Filed January 8, 2007.
Johnny Ayres, pro se.
Susan S. Canavello, for respondent.
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7463 in effect when the petition was filed.1
The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
1Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the year at issue.
The facts are not in dispute, and the issue is a question of law;
therefore, with respect to the burden of proof, the Court need
not address the applicability of sec. 7491. Higbee v.
Commissioner, 116 T.C. 438 (2001).
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