RYAN v. COMMISSIONER

N. THOMAS RYAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

RYAN v. COMMISSIONER

No. 13239-02S

United States Tax Court

T.C. Summary Opinion 2005-118; 2005 Tax Ct. Summary LEXIS 147;

August 10, 2005, Filed

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

N. Thomas Ryan, Pro se.

Francis Mucciolo and Michael D. Zima, for respondent.

Panuthos, Peter J.

PETER J. PANUTHOS

PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition…