T.C. Summary Opinion 2007-201
UNITED STATES TAX COURT
PATRICIA H. DEVLIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8128-05S. Filed November 28, 2007.
Patricia H. Devlin, pro se.
Jack T. Anagnostis, for respondent.
COHEN, Judge: This case was heard pursuant to the
provisions of section 7463 of the Internal Revenue Code in effect
when the petition was filed. 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 trial was conducted by Special Trial Judge Carleton D.
Powell, who died after the case was submitted. The parties have
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