T.C. Summary Opinion 2007-72
UNITED STATES TAX COURT
E. JOAN BIRKEY AND LARRY E. BIRKEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6392-05S. Filed May 9, 2007.
E. Joan Birkey and Larry E. Birkey, pro sese.
Catherine Tyson, for respondent.
FOLEY, Judge: This case was heard pursuant to section 74631
of the Internal Revenue Code. Pursuant to section 7463(b), the
decision to be entered is not reviewable by any other court, and
this opinion shall not be treated as precedent for any other
case. The issue for decision is whether petitioners failed to
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
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Last modified: November 10, 2007