Allen v. Comm'r

HOWARD C. CANTOR AND PATRICIA M. ALLEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Allen v. Comm'r

Docket No. 20858-11S

United States Tax Court

T.C. Summary Opinion 2014-103; 2014 Tax Ct. Summary LEXIS 106;

November 6, 2014, 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 under Rule 155.

Darren Marie Larsen, for petitioners.

Steven Roth, for respondent.

CARLUZZO, Special Trial Judge.

CARLUZZO

SUMMARY OPINION

CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of…