NEWELL v. COMMISSIONER

NELL B. NEWELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

NEWELL v. COMMISSIONER

No. 9839-01S

United States Tax Court

T.C. Summary Opinion 2003-1; 2003 Tax Ct. Summary LEXIS 1;

January 7, 2003, Filed

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

Clarence F. Frazier, for petitioner.

Brandi B. Darwin, for respondent.

Dinan, Daniel J.

Dinan, Daniel J.

DINAN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed. The…