T.C. Summary Opinion 2007-19
UNITED STATES TAX COURT
STUART RAYMOND QUARTEMONT AND VELVET FENNER QUARTEMONT,
Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3584-06S. Filed February 6, 2007.
Stuart R. Quartemont, pro se.
David Cao, for respondent.
JACOBS, Judge: This case was heard pursuant to the
provisions of section 7463 of the Internal Revenue Code in effect
at the time the petition was filed. Unless otherwise indicated,
subsequent section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
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