Brown v. Comm'r

DAVID W. BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Brown v. Comm'r

No. 4887-08S

United States Tax Court

T.C. Summary Opinion 2009-176; 2009 Tax Ct. Summary LEXIS 180;

November 25, 2009, Filed

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

David W. Brown, Pro se.

Marshall R. Jones, for respondent.

Morrison, Richard T.

RICHARD T. MORRISON

MORRISON, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code, as in effect when the petition was filed. 1 Under section 7463(b),…