United States Tax Court December 17, 2003, No. 15754-02S (SMITH v. COMMISSIONER)

T.C. Summary Opinion 2003-167

UNITED STATES TAX COURT

CHARLES W. AND NANCY T. SMITH, Petitioners v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 15754-02S. Filed December 17, 2003.

Charles W. and Nancy T. Smith, pro se.

Susan Smith Canavello, for respondent.

COUVILLION, Special Trial Judge: This case was heard

pursuant to section 7463 in effect at the time the petition was

filed.