United States Tax Court December 13, 2017, 14798-16S (Paul Chen v. Commissioner)

T.C. Summary Opinion 2017-90

UNITED STATES TAX COURT

PAUL CHEN, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 14798-16S. Filed December 13, 2017.

Paul Chen, pro se.

Jason T. Scott, for respondent.

SUMMARY OPINION

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

provisions of section 7463 of the Internal Revenue Code in effect when the

petition was filed.