Richard Mark Hilton - Page 2















                            T.C. Summary Opinion 2007-82                              


                               UNITED STATES TAX COURT                                


                         RICHARD MARK HILTON, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3588-06S.             Filed May 24, 2007.                   


               Richard Mark Hilton, pro se.                                           
               Matthew A. Houtsma, for respondent.                                    


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code.                
          Unless otherwise indicated, subsequent section references are to            
          the Internal Revenue Code as in effect for the year at issue, and           
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.  Pursuant to section 7463(b), the decision to be                 








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