Michael Alan Swanson, Petitioner, and Judith N. Swanson, Intervenor - Page 2

                             T.C. Summary Opinion 2007-9                              


                               UNITED STATES TAX COURT                                


                          MICHAEL ALAN SWANSON, Petitioner,                           
                        AND JUDITH N. SWANSON, Intervenor v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 5412-05S.            Filed January 17, 2007.                


               Michael Alan Swanson, pro se.                                          
               Deborah McIntosh, for intervenor.                                      
               Michael Lloyd, for respondent.                                         


               GOLDBERG, Special Trial Judge:  This is a case arising under           
          sections 6015 and 7463 of the Internal Revenue Code as in effect            
          at the time the petition was filed.  Unless otherwise indicated,            
          subsequent section references are to the Internal Revenue Code of           
          1986 as amended, and Rule references are to the Tax Court Rules             
          of Practice and Procedure.  The decision to be entered is not               





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