§746

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 746 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the year in issue.

ARMEN, Special Trial Judge: This case was -heard pursuant to the provisions of section 746 of the IInternal Revenue Code in effect when the petitio'n.was-filed.1 Pursuant to section 7463 (b) , the decision to be entered is· not reviewable by any Unless otherwise indicated, all subsequent section references are to the Interna Revenue Code in effect for the year i issue, and all Rule r ferences are to the Tax Couit Rulés of Practice and Procedure.

was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewabl-e by any 1 Unless otherwise indicated, .all subsequent section references are to the Internal Revenue Code-in effect for 2005, the taxable year in .

Pursuant to section 746'3(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for an other case .

Pursuant to section 746.3(b), the decision to be entered is not reviewable by.

PANUTHOS, Chief Special Trial Judge :' This case was heard pursuant to the provisions of section 746 of the Internal Revenue Code in effect when the petition Was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 746,3(b) , the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

WHERRY, Judge : This case was heard pursuant to section 746 3 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the decision to be entere d 'All subsequent section references are to the Internal Revenue Code of 1986, as amended and in effect for the tax year at issue.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this o inion shall not be treated as precedent for any other case .

JACOBS, Judge: This case was heard pursuant to the provisions of sec ion 7463 of the Internal Revenue Code in effect when the petition was filed ursuant to section 746 (b) , t he decisión to be en ered is'not reviewable by any other court and this opinion shall not be treated as precedent for any other case.

to section 746 (b), the decision to be entered is not reviewable by any other court, and 'Unless otherwise indicated, subsequent section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure . SERVED Jan 21 2010 2 - this opinion shall not be treated as