T.C. Summary Opinion 2007-187
UNITED STATES TAX COURT
WAYNE SMITH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16263-05S. Filed November 1, 2007.
Frank M. Schuler and Tara Jensen, for petitioner.
Vicki L. Miller, for respondent.
GOLDBERG, Special Trial Judge: This matter was heard
pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect at the time 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. Unless otherwise
indicated, all Rule references are to the Tax Court Rules of
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