Sean Mcalary Ltd, Inc. v. Commissioner

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

T.C. Summary Opinion 2013-62

UNITED STATES TAX COURT SEAN MCALARY LTD, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21068-11S. Filed August 12, 2013. Sean P. McAlary (an officer), for petitioner. Mark H. Pfeffer, for respondent. SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was -2- filed.1 Pursuant to section 7463(b), the decision to be…