Allivato v. Comm'r

LINDA M. ALLIVATO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Allivato v. Comm'r

Docket No. 25733-07S

United States Tax Court

T.C. Summary Opinion 2011-3; 2011 Tax Ct. Summary LEXIS 6;

January 10, 2011, Filed

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

Decision will be entered for respondent.

William B. Clayton, for petitioner.

Audra M. Dineen, for respondent.

PANUTHOS, Chief Special Trial Judge.

PANUTHOS

PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal…