Marc Perkel v. Commissioner

T.C. Summary Opinion 2007-33

UNITED STATES TAX COURT MARC PERKEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5619-04S. Filed March 5, 2007. Marc Perkel, pro se. Catherine G. Chang, for respondent. DEAN, Special Trial Judge: This case was heard pursuant to the provisions of section 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 all Rule references are to the Tax Court Rules of Practice and Procedure. The decision to be…