Timothy Robert Holmes 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 2013-32

UNITED STATES TAX COURT TIMOTHY ROBERT HOLMES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 25078-11S. Filed April 22, 2013. Robert G. Nassau and E. Peter Frick, for petitioner. Luanne S. DiMauro and Debra Lynn Reale, for respondent. SUMMARY OPINION RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed. Pursuant 1 Unless otherwise…