T.C. Summary Opinion 2007-205
UNITED STATES TAX COURT
BRYAN DOUGLAS EMMEL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23348-06S. Filed December 6, 2007.
Bryan Douglas Emmel, pro se.
David L. Zoss, for respondent.
HAINES, 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 other court, and
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and Rule references are to
the Tax Court Rules of Practice and Procedure. Amounts are
rounded to the nearest dollar.
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