United States Tax Court January 14, 2002, No. 2295-00S (Phillips v. Comm'r)

WILLIAM J. PHILLIPS, JR. AND MATRONA A. PHILLIPS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Phillips v. Comm'r No. 2295-00S United States Tax Court 2002 Tax Ct. Summary LEXIS 3; 2002 T.C. Summary Opinion 2; January 14, 2002., Filed *3 PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b), THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. Joseph R.