Diane L. Hargreaves v. Commissioner

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

T.C. Summary Opinion 2013-102

UNITED STATES TAX COURT DIANE L. HARGREAVES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22026-12S. Filed December 11, 2013. Donald P. Edwards, for petitioner. John W. Sheffield, III and Ashley Y. Smith, for respondent. SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the -2- petition was filed.1 Pursuant to section 7463(b),…