Eberly v. Comm'r

ANDREW J. EBERLY AND RUTHANNE E. EBERLY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Eberly v. Comm'r

No. 6926-04S

United States Tax Court

T.C. Summary Opinion 2006-45; 2006 Tax Ct. Summary LEXIS 124;

March 29, 2006, Filed

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b), THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.

Gary C. Randall and James J. Workland, for petitioners.

Catherine L. Campbell, for respondent.

Carluzzo, Lewis R.

LEWIS R. CARLUZZO

CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code…