United States Tax Court March 4, 2014, 18669-11S L (Merwin K. Sigale v. Commissioner)

T.C. Summary Opinion 2014-19

UNITED STATES TAX COURT

MERWIN K. SIGALE, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 18669-11S L. Filed March 4, 2014.

Merwin K. Sigale, pro se.

Derek P. Richman, for respondent.

SUMMARY OPINION

GUY, Special Trial Judge: This case was heard pursuant to the provisions

of section 7463 in effect when the petition was filed.