T.C. Summary Opinion 2007-13
UNITED STATES TAX COURT
WILLIAM H. JORDAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22562-04S. Filed January 22, 2007.
William H. Jordan, pro se.
Robert W. Dillard, for respondent.
COUVILLION, Special Trial Judge: This case was heard
pursuant to section 7463 in effect when the petition was filed.1
1Unless otherwise indicated, section references hereafter
are to the Internal Revenue Code in effect for the year at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure. Sec. 7491 in some instances shifts the burden of
proof to the Commissioner. Petitioner has neither alleged nor
established that he has satisfied the requirements of that
section. To the extent that respondent may have had the burden
of proof in this case, the Court is satisfied that respondent met
that burden.
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