§7463 — Disputes involving $50,000 or less

6015(e)(1)(A), Butler was overruled by Porter v.

Therefore, sufficient grounds exist under Rule 174(b) to overrule petitioners' evidentiary objections .

In addition, the Court referenced Rule 174(b), which provides : "Trials of small tax cases will be conducted as informally as possible consistent with orderly procedure, and any evidence deemed by the Court to have probative value shall be admissible ." The Court then overruled respondent's objection .

Unlike the dollar limitation in section 7463(a) that refers to tax dollars in dispute for each year, period, or taxable event, the limitation in section 7463(f)(2) refers to the amount of unpaid tax involved in a section 6330 collection case .

tha t-axnavarc warn not H i cnilti nri e mmn,lnt Unlike the dollar limitation in section 7463(a) that refers ;, to "the amount of the deficiency placed in dispute,"8 the dollar limitation in section 7463(f)(2) refers to the amount of "inpaid tax" .

Even though the IRS may have presented evidence showing that the correct amount of tax should be $52,995, and therefore that the deficiency should be several hundred dollars more than what is reflected on the deficiency notice, we question whether we have jurisdiction to redetermine a deficiency of more than $8,553.

We will therefore grant respondent's motion t o 8 We express no opinion on whether a taxpayer , in an amended petition, might reduce his or her claim for relief and thereby qualify to proceed under the small tax case procedures of sec .

The Eighth Circuit has held that where de novo review is not applicable, the scope of review in a CDP case is confined to the administrative record.

SUMMARY OPINION URDA, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

Pursuant to section 7463(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.

Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

SUMMARY OPINION GREAVES, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION MARSHALL, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, 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.1 Pursuant to section 7463(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.

SUMMARY OPINION HALPERN, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Chief 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.1 Pursuant to section 7463(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.

SUMMARY OPINION CHOI, 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.1 Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was submitted pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Petition was filed.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

SUMMARY OPINION CHOI, Special Trial Judge: This case was submitted pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION GREAVES, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Chief 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.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

SUMMARY OPINION LANDY, 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.1 Pursuant to section 7463(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.

SUMMARY OPINION LANDY, 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.1 Pursuant to section 7463(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.

SUMMARY OPINION PARIS, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Chief 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.1 Pursuant to section 7463(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.

SUMMARY OPINION PARIS, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Petition was filed.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

SUMMARY OPINION CHOI, Special Trial Judge: This case was brought pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Petition was filed.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

Pursuant to section 7463(b),1 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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was submitted pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Petition was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

SUMMARY OPINION COPELAND, Judge: This case was submitted pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

SUMMARY OPINION NEGA, Judge: This case was heard pursuant to the provisions of section 7463 in effect when the petition was filed.1 Pursuant to section 7463(b), the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.

SUMMARY OPINION PARIS, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Petition was filed.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

SUMMARY OPINION COPELAND, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This collection review case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION WELLS, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION MARSHALL, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Chief 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.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

SUMMARY OPINION WELLS, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION WEILER, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case for the redetermination of a deficiency was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Chief 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.1 Pursuant to section 7463(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.

SUMMARY OPINION WEILER, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(b), the decision to be entered is not 1Unless otherwise indicated, subsequent section references are to the (continued...) Served 07/19/21 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

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.1 Pursuant to section 7463(b), the decision to be entered is not 1Unless otherwise indicated, subsequent section references are to the (continued...) Served 08/23/21 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Served 08/31/21 - 2 - SUMMARY OPINION GUY, 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.1 Pursuant to section 7463(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.

Served 08/17/21 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GREAVES, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code (Code) in effect when the petition was Served 09/13/21 - 2 - filed.1 Pursuant to section 7463(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.

SUMMARY OPINION PUGH, Judge: This case was heard pursuant to section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This collection review case was heard pursuant to the provisions of section 7463 of the 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, all section references are to the Internal (continued...) Served 04/14/21 -2- reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code (Code) in effect when the Served 12/02/21 - 2 - petition was filed.1 Pursuant to section 7463(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.

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.1 Pursuant to section 7463(b), the decision to be entered is not 1Unless otherwise indicated, subsequent section references are to the (continued...) Served 07/19/21 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION LEYDEN, 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.1 Pursuant to section 7463(b), the decision to be entered is not 1Unless otherwise indicated, all section references are to the Internal Revenue Code (Code), as amended, in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition Served 08/17/21 - 2 - was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

Served 01/26/21 - 2 - SUMMARY OPINION1 GREAVES, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code (Code) in effect when the petition was filed.2 Pursuant to section 7463(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.

s heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Served 09/13/21 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This deficiency case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Served 05/10/21 -2- petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION GUY, 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 Served 11/16/21 - 2 - filed.1 Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition Served 08/16/21 - 2 - was filed.1 Pursuant to section 7463(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.

Served 05/19/21 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Chief 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.1 Pursuant to section 7463(b), the decision to be entered is not 1Unless otherwise indicated, section references are to the Internal Revenue (continued...) Served 07/29/21 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this Served 07/26/21 - 2 - opinion shall not be treated as precedent for any other case.

Served 05/19/21 - 2 - Pursuant to section 7463(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.

to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax (continued...) Served 02/10/21 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION NEGA, Judge: These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Served 10/06/21 - 2 - petitions were filed.1 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, 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.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by 1Unless otherwise indicated, all section references are to the Internal (continued...) Served 06/29/21 -2- any other court, and this opinion shall not be treated as precedent for any other case.

heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Served 09/23/21 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION NEGA, Judge: These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the Served 10/06/21 - 2 - petitions were filed.1 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

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.1 Pursuant to section 7463(b), the decision to be entered is not 1Unless otherwise indicated, all section references are to the Internal (continued...) Served 03/08/21 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Chief 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.1 Pursuant to section 7463(b), the decision to be entered is not 1Unless otherwise indicated, section references are to the Internal Revenue (continued...) Served 05/12/21 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Served 08/16/21 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Chief 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.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 years in issue, and Rule references are (continued...) Served 07/01/21 - 2 - reviewable by any other court, and this opinion shall n

SUMMARY OPINION GUY, 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.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by 1Unless otherwise indicated, all section references are to the Internal (continued...) Served 01/21/21 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Mar 11 2020 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Jun 30 2020 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Apr 20 2020 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Jan 06 2020 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect at the time the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Sep 17 2020 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Aug 05 2020 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Aug 18 2020 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, all section references are to the Internal (continued...) SERVED Nov 09 2020 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Feb 18 2020 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Jun 16 2020 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

Unless otherwise indicated, section references are to the Internal Revenue Code (Code) in (continued...) SERVED Aug 03 2020 -2- Pursuant to section 7463(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.

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Petitioner resided in (continued...) SERVED Jan 07 2020 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GERBER, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED May 26 2020 -2- Pursuant to section 7463(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.

SUMMARY OPINION GOEKE, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Feb 10 2020 - 2 - Pursuant to section 7463(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.

We (continued...) SERVED Jan 14 2020 - 2 - Pursuant to section 7463(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.

SERVED Apr 09 2020 - 2 - Pursuant to section 7463(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.

to the provisions of section 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless 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 (continued...) SERVED Aug 27 2020 - 2 - Pursuant to section 7463(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.

SERVED Jan 15 2020 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GERBER, Judge: This case was heard subject to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Jan 30 2020 -2- Pursuant to section 7463(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.

SERVED Jan 21 2020 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This collection review case involving a Federal tax lien was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹All section references are to the Internal Revenue Code of 1986, as (continued...) SERVED Feb 27 2020 - 2 - 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.

ant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the relevant times, and all Rule references are to the (continued...) SERVED Jul 02 2020 - 2 - Pursuant to section 7463(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.

SERVED Jul 22 2020 - 2 - petition was filed.2 Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Jan 16 2020 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.2 Pursuant to section 7463(b), the decision to be entered is not ¹Mr.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹All section references are to the Internal Revenue Code, as amended, in (continued...) SERVED Oct 01 2019 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Jul 02 2019 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

o the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹ All other section references are to the Internal Revenue Code (Code) in effect for the year in issue, and all Rules references are to the Tax Court Rules of (continued...) SERVED Sep 30 2019 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION VASQUEZ, Judge: This case was heard pursuant to the provisions of section 7463 ofthe Internal Revenue Code (Code) in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹All section references are to the Code in effect for the year in issue, and all (continued...) SERVED Jul 01 2019 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SERVED May 02 2019 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION NEGA, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Intemal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Oct 15 2019 - 2 - Pursuant to section 7463(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.

SERVED Apr 04 2019 - 2 - Pursuant to section 7463(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.

SERVED Aug 12 2019 -2- Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Mar 05 2019 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Aug 05 2019 -2- reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

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 and in effect for the relevant period.

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 and in effect for 2015.

SERVED Aug 12 2019 -2- Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Jul 15 2019 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to (continued...) SERVED Mar 04 2019 - 2 - reviewable by any other court, and this opinion shall not be tr

We (continued...) SERVED Dec 03 2019 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, all section references are to the Internal (continued...) SERVED May 02 2019 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Oct 10 2019 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

dollars unless (continued...) SERVED Sep 23 2019 -2- Pursuant to section 7463(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.

SERVED Sep 30 2019 -2- Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code (Code) in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Jul 25 2019 - 2 - not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Nov 04 2019 - 2 - Pursuant to section 7463(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.

Some monetary amounts are rounded (continued...) SERVED Jan 29 2019 - 2 - Pursuant to section 7463(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.

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 and in effect for 2013.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (Code) in effect for the year in issue, and all Rule references are to the Tax (continued...) SERVED Sep 04 2019 - 2 - reviewable by any other court, and this opinion shall not b

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹All section references are to the Internal Revenue Code, as amended, in (continued...) SERVED Apr 02 2019 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

¹Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for 2013, and all Rule references (continued...) SERVED Jun 24 2019 -2- Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Aug 08 2019 - 2 - petition was filed.¹ Pursuant to section 7463(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.

Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986 (26 U.S.C., "the Code") as amended and in effect for the relevant years, and all Rule references are to the Tax Court Rules ofPractice and (continued...) SERVED Mar 18 2019 - 2 - the decision to be ent

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect at the time the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Jul 10 2019 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Aug 20 2019 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Aug 26 2019 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SERVED Aug 27 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 years in issue, and Rule references are to the Tax Court Rules ofPractice and Procedure.

SERVED Apr 04 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, all section references are to the Internal (continued...) SERVED May 30 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

All monetary (continued...) SERVED Nov 01 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Mar 08 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹All section references are to the Internal Revenue Code, as amended, in (continued...) SERVED Apr 05 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GERBER, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by any ¹Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Jul 09 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Mar 06 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION COLVIN, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED Jun 04 2018 - 2 - filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION MORRISON, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code of 1986, as amended, in effect when the petition was filed.¹ ¹All subsequent section references are to the Internal Revenue Code of 1986, as amended, in effect for the year at issue, 2013.

SERVED Dec 06 2018 -2- petitions were filed.2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code of 1986 in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Dec 03 2018 - 2 - entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Jun 06 2018 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SERVED Jan 10 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED May 14 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Apr 03 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED Apr 18 2018 -2- filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Jan 31 2018 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED Oct 04 2018 -2- filed.¹ Pursuant to section 7463(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.

SERVED Dec 06 2018 -2- petitions were filed.2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the taxable year 2015, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax (continued...) SERVED Jun 06 2018 - 2 - Pursuant to section 7463(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.

SERVED Apr 05 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Apr 09 2018 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SERVED Sep 19 2018 -2- Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Dec 03 2018 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SERVED Mar 20 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Dec 26 2018 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SERVED Feb 05 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED May 24 2018 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SERVED Dec 06 2018 -2- petitions were filed.2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED May 16 2018 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, all section references are to the Internal (continued...) SERVED Jul 02 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Mar 06 2018 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Dec 26 2018 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SERVED Nov 08 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION RUWE, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Intemal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Apr 16 2018 - 2 - Pursuant to section 7463(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.

Monetary amounts are rounded to the (continued...) SERVED Aug 07 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED Sep 17 2018 -2- filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Jun 27 2018 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Mar 13 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Nov 05 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Apr 04 2018 -2- reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Sep 17 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Sep 05 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Some monetary amounts are rounded (continued...) SERVED Nov 27 2018 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, all section references are to the Internal (continued...) SERVED Jul 12 2018 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Dec 06 2018 -2- petitions were filed.2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Mar 19 2018 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION RUWE, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Intemal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Aug 13 2018 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Jul 12 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Jul 31 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Mar 13 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Apr 27 2017 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹All section references are to the Internal Revenue Code (Code), as (continued...) SERVED Nov 09 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Mar 08 2017 2 reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Dec 26 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

These consolidated cases were heard pursuant to the provisions of section 7463 ofthe Internal Revenue Code in effect when the petitions were filed.¹ Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Jun 28 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Dec 13 2017 -2- reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Dec 18 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Apr 03 2017 -2- any other court, and this opinion shall not be treated as precedent for any other case.

t to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ 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 (continued...) SERVED May 30 2017 -2- Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Mar 23 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

Rule references are to the Tax Court Rules ofPractice and (continued...) SERVED Apr 25 2017 - 2 - Pursuant to section 7463(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.

SERVED Jul 11 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION PUGH, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹ Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Jun 29 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION WHERRY, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect at the time the petition was filed.¹ The decision to ¹Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect in the year at issue, and all Rule references are to the Tax Court Rules ofPractice and P

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Feb 02 2017 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Dec 04 2017 - 2 - Pursuant to section 7463(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.

These consolidated cases were heard pursuant to the provisions of section 7463 ofthe Internal Revenue Code in effect when the petitions were filed.¹ Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Feb 06 2017 2 petition was filed.¹ Pursuant to section 7463(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.

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 and in effect for the years in issue.

SUMMARY OPINION VASQUEZ, Judge: These consolidated cases were heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Nov 09 2017 - 2 - petition was filed.¹ Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Jul 12 2017 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Sep 11 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED May 11 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Nov 09 2017 -2- any other court, and this opinion shall not be treated as precedent for any other case.

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

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Jun 19 2017 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

¹All 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 ofPractice and (continued...) SERVED Mar 06 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Aug 24 2017 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Oct 03 2017 -2- reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Apr 27 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Feb 08 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Dec 26 2017 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

t to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the year in issue, and all Rule references are to (continued...) SERVED Oct 25 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Feb 13 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Jul 20 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times.

SUMMARY OPINION CARLUZZO, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Oct 04 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Aug 16 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Dec 18 2017 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED Oct 02 2017 - 2 - filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, all section references are to the Internal (continued...) SERVED Aug 17 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Sep 13 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹All section references are to the Internal Revenue Code in effect for the (continued...) SERVED Apr 27 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Aug 10 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION WHERRY, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect at the time the petition was filed.¹ The decision to ¹Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986 (Code), as amended and in effect for the tax year at issue, and all Rule references are to the Tax Court Rules ofPr

nt to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax (continued...) SERVED Jul 24 2017 -2- Pursuant to section 7463(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.

SERVED Dec 27 2017 - 2 - Pursuant to section 7463(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.

SERVED Aug 09 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED May 08 2017 -2- any other court, and this opinion shall not be treated as precedent for any other case.

o the provisions of section 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹ Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years in issue, and all Rule references are to (continued...) SERVED Nov 09 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, all section references are to the Internal (continued...) SERVED Aug 07 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Intemal Revenue Code in effect when the SERVED Jun 26 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SERVED Jan 30 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED May 08 2017 2 reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

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 years in issue.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED May 08 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Jun 12 2017 -2- Pursuant to section 7463(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.

SERVED Jul 17 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Jun 28 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION VASQUEZ, Judge: These consolidated cases were heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Nov 09 2017 - 2 - petition was filed.¹ Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Jul 13 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Jul 20 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GERBER, Judge: This case was heard pursuant to section 7463¹ ofthe Internal Revenue Code in effect when the petition was filed.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹ Unless otherwise indicated, all subsequent section references are to the (continued...) SERVED Mar 30 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal Revenue Code (Code), as amended and in effect for the taxable year 2012, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

SERVED Jul 17 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Dec 04 2017 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Jun 28 2017 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the taxable year 2012, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code of 1986 in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Aug 17 2017 - 2 - not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹All section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules ofPractice and (continued...) SERVED May 25 2017 -2- reviewable by any other court, and this opinion shall not be treat

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 and in effect for the years in issue.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Nov 01 2017 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Aug 29 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED May 23 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Aug 29 2017 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED May 24 2017 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Aug 16 2017 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

All monetary amounts are (continued...) SERVED Mar 13 2017 - 2 - Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion may not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Nov 09 2016 - 2 - 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.

Pursuant to section 7463(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.

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

SUMMARY OPINION GERBER, Judge: This case was heard pursuant to section 7463¹ ofthe Internal Revenue Code in effect when the petition was filed.

Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Sep 26 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Dec 20 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹ Unless otherwise indicated, all subsequent section references are to the (continued...) SERVED Apr 04 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION BUCH, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Under section 7463(b), the ¹Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect at all relevant times, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Oct 06 2016 2 reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect at all relevant times.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect at all relevant times.

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

t to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ 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 (continued...) SERVED Aug 02 2016 -2- Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: Each ofthese consolidated cases was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be ¹Unless otherwise indicated, subsequent section references are to the Intemal Revenue Code of 1986, as amended, in effect for the relevant period.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹All section references are to the Internal Revenue Code in effect for the (continued...) SERVED Aug 24 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SERVED Sep 01 2016 - 2 - Pursuant to section 7463(b), the decision to be entered in not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Aug 15 2016 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Oct 17 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

to the provisions of section 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax (continued...) SERVED May 16 2016 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION RUWE, Judge: The petition in this case was filed pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code.¹ Pursuant to section 7463(b), the ¹All section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

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 and in effect for 2011.

SUMMARY OPINION GUY, Special Trial Judge: These consolidated cases were heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decisions to be entered are not ¹These cases were consolidated for purposes oftrial, briefing, and opinion.

SUMMARY OPINION GUY, Special Trial Judge: These consolidated cases were heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decisions to be entered are not ¹These cases were consolidated for purposes oftrial, briefing, and opinion.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any ¹ Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Aug 08 2016 2 reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the taxable year 2012.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹ Unless otherwise indicated, all subsequent section references are to the (continued...) SERVED Jun 20 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Nov 08 2016 2 reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

ant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years under consideration, and all Rule references (continued...) SERVED Apr 25 2016 - 2 - Pursuant to section 7463(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.

We round all monetary amounts (continued...) SERVED Nov 15 2016 - 2 - Pursuant to section 7463(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.

SERVED Jun 20 2016 - 2 - Pursuant to section 7463(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.

SERVED Aug 08 2016 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Dec 13 2016 -2- any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SERVED Sep 29 2016 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Mar 08 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Nov 08 2016 2 reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION GERBER, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Intemal (continued...) SERVED Jun 23 2016 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION PUGH, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹ Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Jan 11 2016 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹ Unless otherwise indicated, all subsequent section references, as well as all (continued...) SERVED May 12 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Nov 03 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Nov 03 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

All Rule references are to the Tax Court Rules of (continued...) SERVED Sep 26 2016 - 2 - Pursuant to section 7463(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.

nt to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax (continued...) SERVED Nov 16 2016 -2- Pursuant to section 7463(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.

SUMMARY OPINION ASHFORD, Judge: This case was heard pursuant to the provisions of section 7463 ofthe Intemal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Intemal (continued...) SERVED May 12 2016 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION MORRISON, Judge: This case was heard pursuant to section 7463¹ ofthe Internal Revenue Code in effect when the petition was filed.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the Intemal Revenue Code of 1986, as amended, in effect for the years in issue.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Jun 22 2016 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Aug 24 2016 2 reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

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 and in effect for 2010.

Pursuant to section 7463(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.

SERVED Aug 08 2016 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(b), the ¹Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as in effect for the year at issue, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: These consolidated cases were heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petitions were filed.¹ Pursuant to section 7463(b), the decisions to ¹By order dated August 5, 2015, these cases were consolidated.

2Hereinafter, all section references are to the Internal Revenue Code in (continued...) SERVED Aug 25 2016 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ASHFORD, Judge: This case was heard pursuant to the provisions of section 7463 ofthe Internal Revenue Code in effect when the petition was SERVED Aug 17 2016 - 2 - filed.¹ Pursuant to section 7463(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.

SERVED Nov 08 2016 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹ Unless otherwise indicated, all subsequent section references are to the (continued...) SERVED May 26 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Jul 05 2016 -2- Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: These consolidated cases were heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petitions were filed.¹ Pursuant to section 7463(b), the decisions to ¹By order dated August 5, 2015, these cases were consolidated.

SERVED Jan 28 2016 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Sep 27 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SERVED Dec 21 2016 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Sep 15 2016 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION WHERRY, Judge: This case was heard pursuant to the provisions of section 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by any ¹Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the year in issue, and Rule references are to the Tax Court Rules ofPractice and Procedure.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Oct 24 2016 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Dec 19 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: Each ofthese consolidated cases was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be ¹Unless otherwise indicated, subsequent section references are to the Intemal Revenue Code of 1986, as amended, in effect for the relevant period.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED Jan 28 2016 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Aug 02 2016 - 2 - Pursuant to section 7463(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.

SERVED Aug 15 2016 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Mar 09 2016 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Apr 14 2016 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹ Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect at all relevant times.

Pursuant to section 7463(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.

SERVED FEB - 3 20f5 Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED APR 2 0 2015 - 2 - for any other case.

SERVED Nov 24 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(b), the decision to be entered is not 'Unless otherwise indicated, subsequent section references are to the (continued...) SEftVED AUG 1 7 2015 2 reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED APR - 6 2015 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any SERVED Oct 22 2015 -2- other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SEWED APR 2 0 2015 -2- filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by any othercourt, and this opinion shall not be treated as precedent for any other case.

to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless 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 (continued...) SERVED JUN 2 92015 - 2 - Pursuant to section 7463(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.

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 and in effect for 2010.

Pursuant to section 7463(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.

SERVED AUG - 3 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GERBER, Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Dec 21 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION BUCH, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Under section 7463(b), the ¹Unless 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 (continued...) SERVED Jul - 7 2015 - 2 - decis

SUMMARY OPINION KERRIGAN, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.

SERVED Nov 19 2015 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION BUCH, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect at all relevant times, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

Some monetary amounts are (continued...) SBWED JUN - 1 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), IUnless otherwise indicated, all section references are to the Internal (continued...) SERVED AUG - 6 2015 - 2 - 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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED 11AY 1 1 2015 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹ Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2010, the taxable year in issue.

SERVED Dec 02 2015 - 2 - Pursuant to section 7463(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.

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

SERVED FEB - 2 2015 - 2 - SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463.2 Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED APR 20 2015 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Nov 09 2015 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED MAY 1 4 2015 t - 2 - filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Oct 05 2015 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Oct 01 2015 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SEfWED APR 2 1 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GERBER, Judge: These consolidated cases were heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Dec 21 2015 - 2 - petitions were filed.¹ Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION THORNTON, ChiefJudge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED AUG 2 5 2015 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

All Rule references are to the Tax Court Rules of (continued...) SERVED FEB - 5 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effectwhen the SERVED FEB 2 3 2015 - 2 - petition was filed.' Pursuant to section 7463(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.

SERVED APR 13 2015 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION GERBER, Judge: These consolidated cases were heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Dec 21 2015 - 2 - petitions were filed.¹ Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Sep 21 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effectwhen the petition was filed.' 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 years in issue, and Rule references are to the Tax Court Rules ofPractice and Procedure.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Nov 09 2015 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

2Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Dec 10 2015 -2- Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not ¹ Unless otherwise indicated, all subsequent section references are to the (continued...) SERVED Nov 30 2015 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SEVED AUG 1 0 2015 - 2 - Pursuant to section 7463(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.

SERVED JUL 1 4 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED MAR 1 7 2015 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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, subsequent section references are to the (continued...) SERVED Oct 15 2015 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 years in issue.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by SERVED FEB - 3 2015 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue Code, as amended and in effect for 2012, and Rule references are to the Tax Court (continued...) SERVED JUL - 6 2015 -2- any other court, and this opinion shall not be tr

SERVED JUL 1 4 2015 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION NEGA, Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED Mar 25 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION THORNTON, ChiefJudge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹All other section references are to the Internal Revenue Code in effect at all relevant times.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED SEP - 8 2015 -2- any other court, and this opinion shall not be treated as precedent for any other case.

to the provisions ofsection 7463 ofthe Internal Revenue Code in effectwhen the petition was filed.¹ ¹Unless 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 (continued...) SERVED MAR 3 7 2015 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Dec 02 2015 -2- any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION KERRIGAN, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.

SEVED FEB 1 1 2015 -2- Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by 'Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED FEB 2 4 2015 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 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 (continued...) SERVED AUG 2 4 2015 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for.any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED JUN 2 3 2014 -2- filed.¹ Pursuant to section 7463(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.

SERVED FEB 25 2014 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED JUN - 4-2014 - 2 - petition was filed.' Pursuant to section 7463(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.

¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED MAR 2T 2014 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED MAR 1 0 2014 - 2 - petition was filed.¹ Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SEfWED MAY 1 2 2014 - 2 - for any other case.

Pursuant to section 7463(b), the decision to be entered is not .

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED DEC 2 22014 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SERVED AUG 1 3 2014 -2- Pursuant to section 7463(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.

2Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue and all Rule references are to the Tax (continued...) SERVED NOV 10 2014 - 2 - Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Jul 28 2014 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue Code (Code), as amended and in effect for 2009, and Rule references are to the (continued...) SERVED FEB 0 3 2014 - 2 - any other court, and this opinion shall not be tre

Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 in effect when the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED JUN 1 1 2014 - 2 - 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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED AUG 2 8 2014 -2- any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

SERVED NOV 1 0 2014 - 2 - Pursuant to section 7463(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.

2Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue and all Rule references are to the Tax (continued...) SERVED NOV 10 2014 - 2 - Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

2Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue and all Rule references are to the Tax (continued...) SERVED NOV 10 2014 - 2 - Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code (Code) in effectwhen the SERVED FEB 1 9 2014 - 2 - petition was filed.' Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED Jun 16 2014 - 2 - for any other case.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SS JAN 1 5 2014 - 2 - for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by 1Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED JAN - 6 2014 - 2 - .

to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ ¹Unless 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 (continued...) SERVED JUL 1 0 2014 - 2 - Pursuant to section 7463(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.

SERVED JUN 2 4 2014 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SERVED JAN 1 5 2014 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special 'Irial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Jun 19 2014 - 2 - petition was filed.' Pursuant to section 7463(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.

¹Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the (continued...) SERVED FEB 2 4 2014 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: These consolidated cases were heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effectwhen the petitions were filed.¹ Pursuant to section 7463(b), the decisions to be entered are ¹These cases were consolidated for purposes oftrial, briefing, and opinion.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treatyd as precedent SERVED MAR 2 7 2014 - 2 - for any other case.

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

SERVED JUL 1 6 2014 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463.¹ Pursuant to section 7463(b), the decision to be ¹ Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the time that the petition was filed, and all Rule (continued...) SWF0 MAY 1 2 20f4 - 2 - entered is not reviewable by any other court, and this opinion shall not be treated as

Pursuant to section 7463(b), 'Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986 as in effect for the year in issue (codified in 26 U.S.C., and referred to herein as "the Code"), and all Rule references are to the Tax Court Rules ofPractice and Procedure.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SEflVED SEP - 3 2014 -2- petition was filed.¹ Pursuant to section 7463(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.

Pursuant to section 7463(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.

SERVED DEC 2 3 2014 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION MORRISON, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.

SUMMARY OPINION ARMEN, Special Trial Judae: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED MAR 1 1 2014 - 2 - petition was filed.' Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Jul 28 2014 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: These consolidated cases were heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effectwhen the petitions were filed.¹ Pursuant to section 7463(b), the decisions to be entered are ¹These cases were consolidated for purposes oftrial, briefing, and opinion.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED JUL 3 6 20% - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effectwhen the SERVED JUN 2 4 2014 - 2 - petition was filed.¹ Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable bh any other court, and this opinion shall not be treated as precedent for any other càse.

SUMMARY OPINION THORNTON, ChiefJudge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(b), the decision to be entered is not reviewable by 'All section references are to the Internal Revenue Code in effect for the (continued...) SERVED FEB 1 1 2014 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED APR 2 2 2014 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED NOV - 6 2014 -2- petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 in effectwhen the petition was filed.¹ Pursuant to section 7463(b), ¹Unless otherwise indicated, all section references are to the Internal (continued...) SERVED SEP 2 4 2014 -2- 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.

Pursuant to section 7463(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.

Pursuant to section 7463(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.

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

SUMMARY OPINION THORNTON, ChiefJudge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effectwhen the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by 'All section references are to the Internal Revenue Code in effect for the relevant times, and all Rule references are to the Tax Court Rules ofPractice and (continued...) SERVED Apr 16 2014 - 2 - any other court, and this opinion shall not be tr

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED FEB 1 9 2014 - 2 - petition was filed.' Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SWED MAR - 6 2014 6 - 2 - for any other case.

We round all dollar (continued...) SERVED Apr 17 2014 2 Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED JAN - 9 2014 - 2 - petition was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION LAUBER, J_udge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code.' Pursuant to section 7463(b), the decision to 1All statutory references are to the Internal Revenue Code in effect at the relevant times, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.¹ Pursuant to section 7463(b), the decision to be entered is not reviewable by ¹Unless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED AUG 1 1 2014 -2- any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effectwhen the SERVED Aug 25 2014 - 2 - petition was filed.¹ Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(b), the decision to be entered is not ¹Unless otherwise indicated, subsequent section references are to the Internal Revenue Code of 1986, as amended, in effect for 2010.

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

SERVED SEP 2 3 2014 - 2 - Pursuant to section 7463(b), the decision to be entered is notreviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION KERRIGAN, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.

YBfWED MAR 2 5 200 - 2 - effect when the petitions were filed.2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED DEC - 5 2013 - 2 - for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the - 2 - petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED DEC - 9 2013 - 2 - petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by 1Section references are to the Internal Revenue Code (Code), as amended (continued...) SERVED OCT 2 3 2013 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED APR 29 2013 - 2 - filed.' Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVEDMay212013 - 2 - petition was filed.' Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED MAR 2 8 2013 - 2 - petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION HAINES, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 1Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the relevant times.

(continued...) - 2 - Pursuant to section 7463(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.

the provisions of section 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years in issue, and all Rule references are to (continued...) SERVED JAN - 2 2013 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVEb FEB 20 2013 - 2 - petition was filed.' Pursuant to section 7463(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.

MfED JUN 1 0 2013 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION HAINES, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 1Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the taxable year at issue, and all Rule references are to the Tax Court Rules ofPractice and Pro

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated SERVED JUL - 3 2013 - 2 - as precedent for any other case.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED NOV - 4 2013 - 2 - for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED Sep 26 2013 - 2 - filed.) Pursuant to section 7463(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.

SERVED AUG 1 3 2013 - 2 - Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED JAN 3 0 2013 - 2 - petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the D îlR1 3 2013 - 2 - petition was filed.i Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED MAR 1 9 2013 - 2 - petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION HAINES, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Pursuantto section lUnless otherwise indicated, all section references are to the Internal Revenue Code (Code), as amended and in effect for the year at issue, and all Rule references are to the Tax Court Rules ofPractice and Proce

Pursuant to section 7463(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.

SUMMARY OPINION HAINES, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuantto section 'Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect at all relevant times.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED DEC 172013 - 2 - filed.' Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED Nov - 4 2013 - 2 - for any other case.

05RVED QUN- 1 0 20u - 2 - petition was filed.2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED Apr 17 2013 - 2 - for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the AVED [dAN 7 200 - 2 - petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED JUN 25 2013 - 2 - petition was filed.' Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated SERVED JUL - 3 2013 - 2 - as precedent for any other case.

Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED Apr 16 2013 - 2 - filed.' Pursuant to section 7463(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.

Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the year in issue, and all Rule (continued...) SERVED Mar 04 2013 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not i Unless otherwise indicated, all subsequent section references are to the (continued...) SERVED Sep 26 2013 - 2 - reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED FEB 20 2013 - 2 - petition was filed.' Pursuant to section 7463(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.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED AUG 1 2 2013 - 2 - filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, SERVED May 20 2013 - 2 - and this opinion shall not be treated as precedent for any other case.

05RVED QUN- 1 0 20u - 2 - petition was filed.2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to,the provisions ofsection 7463 in effect when the petition was filed.1 Pursuant to section 7463(b), lAll section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules ofPractice and Procedure.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SiiRVED AUG 1 5 2013 - 2 - filed.1 Pursuant to section 7463(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.

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

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED DEC -9 2013 - 2 - petition was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' 'Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax (continued...) SERVED SEP - 5 2013 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION VASQUEZ, Judge: This case was heard pursuant to the provisions of section 7463 ofthe Internal Revenue Code (Code) in effect when the petition was SERVED MAY - 7 2013 - 2 - filed.1 Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED NOV 2 0 2013 - 2 - petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION BUCH, Judge: These cases were heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petitions were filed.' Pursuant to 1Unless otherwise indicated, all section references are to the Internal (continued...) SERVED NOV 18 2013 - 2 - section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion may

YBfWED MAR 2 5 200 - 2 - effect when the petitions were filed.2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SiiRVED JUL 1 5 2013 - 2 - filed.1 Pursuant to section 7463(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.

SUMMAI Y ÓPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVÉD JUN 3 2013 -2- petition was filed.' Pursuant to section 7463(b), the decision o be entered is not reviewable by any other court, and this opinion shall not be tr ated as precedent for any other case.

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

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by 1Unless otherwise indicated, section references are to the Internal Revenue (continued...) eæE; NOV 2 6 2013 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED JUL 1 8 2013 - 2 - for any other case.

SUMMARY OPINION HAINES, Judae: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 'Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the taxable years at issue, and all Rule (continued...) SERVED MAR - 4 20I3 - 2 - 7463(b), the

Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED NOV 1 4 2013 -2- for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was SERVED Apr 08 2013 - 2 - filed.' Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED NOV _ 6 2013 - 2 - for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the S§RVED OCT 2 1 2013 - 2 - petition was filed.1 Pursuant to section 7463(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.

SERVED JUN 2 4 2013 - 2 - petition was filed.2 Pursuant to section 7463(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.

Pursuant to section 7463(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.

SERVED AUG 1 3 2013 - 2 - Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by ISection references are to the Internal Revenue Code (Code), as amended, (continued...) SERVED Jun 18 2013 - 2 - any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION BUCH, Judge: These cases were heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petitions were filed.' Pursuant to 1Unless otherwise indicated, all section references are to the Internal (continued...) SERVED NOV 18 2013 - 2 - section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion may

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

!; ggBVED MAY 2 9 2013 - 2 - Pursuant to section 7463(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.

YBfWED MAR 2 5 200 - 2 - effect when the petitions were filed.2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED Feb 07 2013 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION BUCH, J_udge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Under section 7463(b), the 1Unless 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 ofPractice and Procedure.

SUMMARY OPINION KERRIGAN, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.

SUMMARY OPINION LAUBER, Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code.1 Pursuant to section 7463(b), the decision to 1All statutory references are to the Internal Revenue Code of 1986, as amended and in effect for the tax years at issue.

SUMMARY OPINION HAINES, Judge: This case was heard pursuant to section 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuantto section 'Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the taxable years at issue, and all Rule references are to the Tax Court Rules ofPractice and Proc

S ARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect véhen the pERVED DEC 112013 - 2 - petition was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

Pursuant to section 7463(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 SERVED JUL - 3 2013 - 2 - case.

SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Ínternal Revenne Code in effect when the petition was SERVED MAY 2 8 2013 -2 - filed.1 Pursuant to section 7463(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.

e was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' '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 (continued...) - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

SUMMARY OPINION VASQUEZ, Judge: This case was heard pursuant to the provisions of section 7463 ofthe Internal Revenue Code (Code) in effect when the petition was SERVED MAY .- 9 2013 - 2 - filed.i Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED DEC - 2 2013 - 2 - petition was filed.i Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as SERVED AUG 1 3 20I1 - 2 - precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: The petition in this case was filed pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(b), the decision to be 1Unless otherwise indicated, section references are to the Internal Revenue (continued...) ~ SERVED JUL 1120D - 2 - entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

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

Pursuant to section 7463(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.

SERVEDOct162012 - 2 - Pursuant to section 7463(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.

SMED AUG 2 3 2012 - 2 - Pursuant to section 7463(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.

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

nt to the provisions of section 7463 ofthe Internal Revenue Code in effect when the petition was filed.' 'Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986 as amended and in effect for the taxable year at issue, and (continued...) SERVED NOV ' 1 2012 - 2 - Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion should not be treated as precedent for any other case.

Pursuant to section 7463(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.

SERVED MAR 2 7 2012 - 2 - SUMMARY OPINION GERBER, Judae: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(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.

-2- Pursuant to section 7463(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.

Pursuant to section 7463(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.

SERVED Dec 26 2012 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure.

RVEB JAN 26 2012 - 2 - SUMMARY OPINION DAWSON, Judge: This case was heard pursuant to the provisions of section 7463 ofthe Internal Revenue Code in effect when the petition was filed.i Pursuant to section 7463(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.

OBlWEB QUL 1 6 2012 - 2 - Pursuant to section 7463(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.

SERVED FEB - 1 2012 -2- SUMMARY OPINION LARO, Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code (Code) in effect when the petition was filed.' Pursuant to section 7463(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.

Pursuant to section 7463(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.

Koprowski signed the - 4 - petition, on which they elected to have the case proceed under small tax case procedures pursuant to section 7463.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this op nion shall not be treated as precedent - 2 - for any other case.

suantto the provisions of section 7463 ofthe Internal Revenue Code in effectwhen the petition was filed.1 1Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code of 1986, as amended and in effect for the taxable year at (continued...) SERVED JEP 4 2012 - 2 - Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion should not be treated as precedent for any other case.

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

Pursuant to section 7463(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.

SUMMARYOPINION ARMEN, Special'Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED .8EPm 5 2012 - 2 - petition was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

SERVED FEB 29 2012 - 2 - SUMMARY OPINION GERBER, Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

ARMEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all 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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Jul 09 2012 - 2 - petition was filed.1 Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: Each ofthese consolidated cases was heard pursuant to the provisions ofsection 7463.1 Pursuant to section 7463(b), the IUnless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Sep 17 2012 -2- decision to be entered in each case is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARYOPINION ARMEN, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Interna} Revenue Code in effect when the - 2 - petition was filed.i Pursuant to section 7463(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.

SERVED FEB 2 8 2012 - 2 - SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

GALE, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for ahy other case.

Pursuant to section 7463(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.

Pursuant to section 7463(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.

SERVED DEC 26 2012 -2- Pursuant to section 7463(b), the decision to be entered is not renewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED MAR 2 1 2012 Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463.1 Pursuant to section 7463(b), the decision to be 1Section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Oct 10 2012 - 2 - petition was filed.1 Pursuant to section 7463(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.

SERVED MAR -12012 - 2 - Pursuant to section 7463 b), the decision to be entered is not reviewable by any other court, and this opin on·shall not be treated as precedent for any other case.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the EVED - - 2 - petition was filed.' Pursuant to section 7463(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.

provisions ofsection 7463.1 Pursuant to section 7463(b), the decision to be 'Unless otherwise indicated, section references are to the Internal Revenue Code in effect when petitioner filed her petition or incurred her administrative and litigation costs, as appropriate, and Rule references are to the Tax Court Rules of Practice and Procedure.

' SERWD EB 27 2012 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This casé was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(b), the decision to be entered is not 'Unless otherwise indicated, subsequent section references are to the (continued...) SERVED OCT 2 5 2012 -2- reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

$ERVED MAY -8 2012 - 2 - Pursuant to section 7463(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.y The instant case is before the Court on respondent's motion for summaryjudgment pursuantto Rule 121.

Pursuant to section 7463(b), the decision to be entered is not SERVED Sgp 3 3797 - 2 - reviewable by any otl er court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this op nion shall not be treated as precedent - 2 - for any other case.

SERVED t%Y -2 2012 - 2 - petition was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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.

ARMEN, 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.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all 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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heardpursuant to the provisions ofsection 7463.1 Pursuant to section 7463(b), the decision to be 1Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

SUMMARY OPINION CARLUZZO, Special Trial Judge: Each ofthese consolidated cases was heard pursuant to the provisions ofsection 7463.1 Pursuant to section 7463(b), the IUnless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Sep 17 2012 -2- decision to be entered in each case is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the NavED OCT 3 1 2012 - 2 - petition was filed.' Pursuant to section 7463(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.

SERVED HAY 21 2012 - 2 - Pursuant to section 7463(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.

SUMMARY OPINIÓN COHEN, Judge: This case was heard pursuantto the provisions ófsection 7463 ofthe Internal Revenue Code in effect when the petition was filed Pursuant to section 7463(b), the decision to be entered is not reviewable by any o her court, and this opinion shall not be treated as precedent for any other case.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case vias heard pursuant to the provisions ofsection 7463.1 Pursuant to section 7463(b), the decision to be 'Unless otherwise indicated, subsequent section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the EYED ÜÜL 1 7 2012 - 2 - petition was filed.1 Pursuant to section 7463(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.

I SERVED AN 3 1 2012 -2- SUMMARYOPINION DAWSON, Judge: This case was heard pursuant to the provisions of section 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

Pursuant to section 7463(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 SERVED JUN 2 6 2012 case.

SUMMARY OPINION SWIFT, Judae: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect whenthe petition was filed.1 IUnless otherwise noted, all section references are to the Internal Revenue (continued...) SERVED DEC (cid:0)57626012 -2 - Pursuant to section 7463(b), the decisionto be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent SERVED AUG -9 2012 for any other case.

Pursuant to section 7463(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.

SERVED Jun 13 2012 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION SWIFT, Judae: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.1 1Unless otherwise indicated,iall section references are to the Intefnal (continued...) SERVED DEC 2 6 2012 - 2 - Pursuant to section 7463(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.

SERVED Nov 06 2012 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuantto the provisions ofsection 7463.1 Pursuant to section 7463(b), the decision to be 1Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

$ERVED DEC 10 2012 - 2 - Pursuant to section 7463(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.

Saavao 3AR e 2012 - 2 - Pursuant to section 7463(b),1 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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED Nov 13 2012 - 2 - petition was filed.' Pursuant to section 7463(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.

SUMMARY OPINION PANUTHOS, ChiefSpecial Trial Judge: This case was heard pursuantto the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SERVED OCT 3 T 202 - 2 - petition was filed.1 Pursuant to section 7463(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.

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

Pursuant to section 7463 (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.

SUMMARY OPINION CARLUZZO, Special Trial Judge: Each ofthese consolidated cases was heard pursuant to the provisions ofsection 7463.1 Pursuant to section 7463(b), the IUnless otherwise indicated, section references are to the Internal Revenue (continued...) SERVED Sep 17 2012 -2- decision to be entered in each case is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

SERVED JAN 25 2012 - 2 - SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the SEaVED AUG -8 2012 - 2 - petition was filed.i Pursuant to section 7463(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.

BERVED AUG - 6 2012 - 2 - Pursuant to section 7463(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.

SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the provisions ofsection 7463 ofthe Internal Revenue Code in effect when the petition SERVED Mar 12 2012 was filed.' Pursuant to section 7463(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.

SERVED JUN 25 2012 - 2 - Pursuant to section 7463(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.

Pursuant to section 7463(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.

Pursuant to section 7463(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.

SWIFT, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any other court, and IUnless otherwise indicated, all section references are to the Internal Revenue Code in effect for 2006, and all Rule references are to the Tax Court Rules of Practice and Procedure.

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

Pursuant to section 7463 (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.

Pursuant to section 7463 (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 - 2 - case.

LARO, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision Subsequent section references are.

Pursuant to section 7463(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.

LARO, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (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.

ARMEN, 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.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 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 7463(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.

RVED JUN 27 2011 - 2 - effect when the petition was filed.2 Pursuant to section 7463 (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.

GERBER, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any 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 7463 (b) , the decision' to be entered is not reviewable by any other court, and tihi-s opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

Pursuant to section 7463(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.

HAINES, Judge: This dase was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure.

ARMEN, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time that the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

GERBER, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (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 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year under consideration.

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

Pursuant to section 7463 (b) , the decision to be entered is not reviewable by IUnless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended.

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

ARMEN, 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.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 Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitionswas ,filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by IUnless otherwise indicated all section- re'ferencei are to the Internal Revenue Code in effect for the year in issue.

Pursuant to section 7463 (b) , the decisions to be entered are not reviewable by any other Court, and this opinion shall not be treated as precedent for any other case.

GERBER, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b) , the decision to be entered.is not reviewable by any other court, and IUnless otherwise indicated, all section references are to the Internal Revenue Code in effect for' the year under consideration.

ARMEN, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time that the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Pursuant to section 7463(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.

WELLS, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (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 1Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, and Rule references are to the Tax Court Rules of Practice an

Pursuant to section 7463(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.

ARMEN, 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.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 Internal Revenue Code in effect for the year in issue.

PANUTHOS, Chief 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.1 Pursuant to section 7463 (b) , the decision to be enzered is not reviewable by IUnless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.

GERBER, Judge : This case was' hÉaÊd pursuant to the provisions of section 7463 of the Internal Revenue Code irî eff ect when the petition was filed.1 Pursuant to section 7463 (b), the 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 2007, the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

MEN, 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.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any Unless ot herwise indicated, all subsequent section references are to the Internal Revenue Code in effect for the year :Ln lSSue .

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.

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

PANUTHOS, Chief 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.' Pursuant to section 7463 (b) , the decision to be entered is not reviewable by IUnless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue.

LARO, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision Subsequent section references are to the applicable versions of the Internal Revenue Code.

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

GOEKE, Judge: This case was heard pursuant to the I provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b) , the All section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Pursuant to section 7463(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.

ARMEN, 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.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 Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

WELLS, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the 1Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, and Rule references (continued.

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

Pursuant to section 7463(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.

Cook, for respondent.' ARMEN, 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.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 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 7463 (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.

Feldhammer, for respondentv HAINES, Judge : This case was heard pursuá.nt to section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered 1Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463 (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.

ARMEN, 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.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all 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.

MARVEL, Judge: This case was heard pursuant to the provisions of section 7463 ,of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any other court, and IUnless otherwise indicated, all section references are to the Internal Revenue Code, as amended, inlâffect for the relevant period, and all Rule references are to the Tax Court Rùles of Practice and Procedure.

HAINES, Judge: This case was heard pursuant to section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (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.

Pursuant to section 7463 (b) , the decisions to be entered are not reviewable by any other Court, and this opinion shall not be treated as precedent for any other case.

ARMEN, Special Trial Judge: This case was heard pursuant to tile provisions of sections 6330 (d) (1) and 7463 (f) (2) .I Pursuant to section 7463 (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.

Pursuant to section 7463(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.

PANUTHOS, Chief Special Trial Judge: T13is case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.

CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any other court, Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

MORRISON, Judge: This case was heard pursuant to section 7463 of the Internal Revenue Code in effect when the petition was filed.

HAINES, Judge: This case was heard pursuant to the provisions of section 7463 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 any other court, and Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure.

HAINES, Judge: These consolidated cases were heard pursuant I to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed.1 Pursuant to section 7463 (b) , the decisions to be entered are not reviewable by any Unless otherwise indicated, section references are to the Internal Revenue Code as amended and in effect for the years in issue.

Pursuant to section 7463 (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.

SWIFT, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 2008.

Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any other court, and this opinion shall snot be treated as precede$t for any other case.

SWIFT, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b), the decision to be entered is not reviewable by any other court, and 1All section references are to the Internal Revenue Code in effect for the year in issue.

Pursuant to section 7463 (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.

Pursuant to section 7463 (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.

Pursuant to section 7463(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.

Pursuant to section 7463 (b), the decision to Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.

PARIS, Judge: This case was heard pursuant to section 7463 of the Internal Revenue Code in effect when the petition was filed.

GALE, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any other court,.

Pursuant to section 7463 (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.

ARMEN, 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.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 Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Pursuant to section 7463 (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.

HAINES, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and 1Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure.

HAINES, Judge: This case was heard pursuant to section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(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.

ARMEN, 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.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Pursuant to section 7463(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.

ARMEN, 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.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any i Unless otherwise indicated, all 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.

Pursuant to section 7463(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.

LARO, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (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.

HAINES, Judge: These consolidated cases were heard pursuant I to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed.1 Pursuant to section 7463 (b) , the decisions to be entered are not reviewable by any Unless otherwise indicated, section references are to the Internal Revenue Code as amended and in effect for the years in issue.

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

Pursuant to section 7463 (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.

Pursuant to section 7463(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.

GERBER, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b), the decision to be entered is not reviewable by any other court, and 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.

ARMEN, 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.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 Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463 (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.

Pursuant to section 7463(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.

WELLS, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not.

CHIECHI, Judge: This case was heard pursuant to the provi- sions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the deci- sion to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

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

Pursuant to section 7463(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.

Pursuant to section 7463(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.

Pursuant to section 7463(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.

Pursuant to section 7463 (b) , the decisions to be entered are not reviewable by any other Court, and this opinion shall not be treated as precedent for any other case.

Pursuant to section 7463(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.

DAWSON, Judge: The petition' in this case was filed pursuant to the provisions of section 7463.1 Pursuant to section 7463(b),.

This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code (Code) in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered.

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

HAINES, Judge: This case was heard pursuant to the provis i.ons of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b) , è.he decisièn to be entered is not reviewable by any other court, and Unless otherwis indicated, section references are to the Internal Revenue Code as amended.

CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7463.1 Pursuant to section 7463 (b), the decision to be entered is not reviewable by any other court, 1Unless otherwise indicated,.

CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 5463.1 Pursuant to section 7463 (b), the decision to be entered is not reviewable by any Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

GERBER, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 2001 and 2002, the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7463.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, 1Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

PANUTHOS, Chief 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.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by 1Unless 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 AUG 2 9 2011 - 2 - Pursuant to section 7463(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.

PANUTHOS, Chief 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.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by 1Unless 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.

HAINES, Judge : This case was heard pursuant to the provision of section 7463 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 any other court, and 'Unless otherwise indicated, section references are to the Internal Revenue Code as amended and in effect for the year in issue .

CARLUZZO, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court , 'Unless otherwise indicated, subsequent section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

ARMEN, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 of thelInternal Revenue Code in effect'when the petition was filed .' Pursuant to section 7463(b), the decision to be entered-is' not reviewable by any 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue'Code in effect for the year in issue .

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as preceden t SERVED Aug 23 2010 2 - for any other case .

Pursuant to section 7463(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 .

Pursuant to section 7463 (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.

ARMEN, 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 .l Pursuant to section 7463(b), the decision to be entered is not.

CHIECHI, Judge : This case was heard pursuant to the provi- sions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the deci- sion to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

MORRISON, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by any Unless otherwise indicated, all ssection references are to the Internal Revenue Code (Code) in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Pursuant to section 7463 (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.

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y ' Unless otherwise indicated, all 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 .

WELLS, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b), the All section references are to the Internal Revenue Code (Code) in effect for the year in issue, and all Rule references are to the Tax Court Rules of Práctice and Procedure, unless otherwise indicated.

Pursuant to section 7463 (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.

Pursuant to section 7463 (b), the decision to be ente'red is not reviewable by any other court, All section references are to' the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice an-d Procedure, unless otherwise indicated.

Pursuant to section 7463(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 .

ARMEN, 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.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 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 7463(b), the decision to be(cid:127)entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

CHIECHI, Judge : This case was heard pursuant to the provi- sions of section 7463 of the Internal Revenue Code in effect when the'petition was filed .' Pursuant to section 7463(b), the deci- sion to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(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 .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, an d 'Unless otherwise indicated, all .section references are to the Internal Revenue Code in effect for 2006, the taxable year in issue, and all Rule references are to-the Tax Court Rules of Practice and Procedure .

ARMEN, 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.' 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 Internal Revenue Code of 1986., as-amended, and all Rule references are to the Tax Court Rules of Practice and Procedure .

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

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

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

Judge : This case was heard pursuant to section 7463 .1 The decision to be entered is not reviewable by any other 'Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1986 as in effect for proceedings commenced on the date the petition in the instant case was filed, except that the section references in

Pursuant to section 7463(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 .

heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period .

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y ' Unless otherwise indicated, all 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 .

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

Pursuant to section 7463 (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.

CHABOT, Judge: These cases were heard pursuant to section 7463.1 The decisions to be entered are not reviewable by any other court, and this opinion- shall not be treated as a precedent for any other case.

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered i not reviewable by any 1 Unless otherwise indicated, all 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 .

Pursuant to section 7463 (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.

LARO, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, and this opinion shall not be treated as precedent for-any other case .

DAWSON, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition, was filed .' Pursuant to section 7463(b), the decision to be entered-is not reviewable by an y 'Unless otherwise indicated, section references are to the Internal Revenue Code, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463 (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.

Pursuant to section 7463(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 .

SERVED Oct 28 2010 - 2 - Pursuant to section 7463 (b), the decision tol be entered in each case 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 the provisions of section 7463 of the Internal Revenu e Code in effect when the petition .was filed.' Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, an d 'Unless otherwise indicated, all section references are to the Internal Revenue Code of 198;6, as amended and in effect for the tax year at issue .

section 7463 of the Internal .Fevenue Code in effectwhen_the petition was filed .' Pursuant to section 7463(b), .the decision to be entered is not reviewable b y .'Unless otherwise indicated,-all-section references are to the internal Revenue Code in effect for the year in issue .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

MORRISON, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, and 'All section references are to the Internal Revenue Code (Code) in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated .

Pursuant to section 7463(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 .

1 Pursuant to section 7463(b), the decision 'Unless otherwise indicated, subsequent section references are to the Internal Revenue Code in effect for the year in issue, and Rule referencesI are to the Tax Court Rules of.Practice and Procedure .

ARMEN, 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 .' 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 Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

ARMEN, Special Trial.Judcge : This case was heard pursuant to the provisions of section 7463 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 any 1 Unless otherwise indicated, all 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.

CARLUZZO, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in .

Pursuant to section 7463 (b), the decision to Unless otherwise indicated, all section references are to the Internal- Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Pursuant to section 7463(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 .

PANUTHOS, Chief 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.1 Pursuant to section 7463 (b) , the decision to be entered is not reviewable by IUnless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended.

ARMEN, 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.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 Internal Revenue Code in effect for 2006, the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

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

CHABOT, Judge: These cases were heard pursuant to section 7463.1 The decisions to be entered are not reviewable by any other court, and this opinion- shall not be treated as a precedent for any other case.

WELLS, Judge: This case was heard pursuant to the provisions-of section '7463 of the Internal Revenue Code in effect when the petition was filed.1 - Pursuant to section 7463 (b) , the All section references are to the Internal Revenue Code (Code) in effect for the year'in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

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

SERVED Dec 28 2010 - 2 - Revenue Code in effect when the petition was filed.2 Pursuant to section 7463 (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.

Pursuant to section 7463 (b)., the decision to 'Unless otherwise indicated , all-section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

JACOBS, Judge : This case was heard pursuant-to the provisions of section 7463 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 any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463 (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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

DEAN, 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 ., Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

LARD, judge : This case was heard pursuant to the provision s of section 7463 of the Internal Revenue Code in effect when th e petition was filedJ1 Pursuant to section 7463(b), the, decision to be entered is nolt reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Code in effect when the petition was filed .' Pursuant to section 7463(b), the deci- sion to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

ARMEN, 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 .' 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 Internal Revenue Code in effect for the year in issue .

Pursuant to section 7463(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 .

Pursuant to section 7463 (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.

Pursuant to section 7463(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 .

GERBER, Judge : This case was heard pursuant to the : .provisions of section 7463 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 any other court, an d 'Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue .

Pursuant to section 7463 (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.

provisions of section 7463 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 any- Unless otherwise indicated, all 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.

MARVEL, Judge : This case was heard pursuant to the provisions of section 7463 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 any-other court, an d 'Subsequent section references are to the Internal Revenue Code, as amended, in effect for the relevant period .

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

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

ARMEN, 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 .l Pursuant to section 7463(b), the decision to be entered is not reviewable by any 1 Unless otherwise.

ARMEN, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code i n effect when the petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y ' Unless otherwise indicated, all 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 .

Pursuant to section 7463(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.

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be enteredis not reviewable by any 1 Unless otherwise indicateid, all 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 .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect SERVED APR 212010 - 2 - when the petition was filed .' Pursuant to section 7463(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 .

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

ARMEN, 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.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 Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

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

Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, an d 'Unless otherwise indicated, all section references are to the Internal Revenue Code in,effect for 2006, the taxable year in issue .

VASQUE Judge : This case was heard pursuant to the provisions f section 7463 of the Internal Revenue Code (Code) in effect when the petition was filed .' Pursuant to section 7463 (b), th~ decision to be entered.

THORNTON, Judge : These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed .' Pursuant to section 7463(b), the decisions to be entered are no t 'Unless otherwise indicated, all section references are to the Internal Revenue Code .

ARMEN, 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 .' Pursuant to section 7463 (b), the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all subsequent section references.

Pursuant to section 7463(b), the decision to be entered is not reviewable 'Unless otherwise indicated, section .

Pursuant to section 7463(b), the decision to be entered is not reviewabl e 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

Pursuant to section 7463(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 .

Pursuant to section 7463(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.

Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 'Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

Pursuant to section 7463(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.

{ ARMEN, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time that the petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by 1 Unless otherwise indicated, all 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 .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in(cid:127)effect when the petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by any 'Unless otherwise indicated,.

Pursuant to section 7463(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 .

THORNTON, Judge : These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed .' Pursuant to section 7463(b), the decisions to be entered are no t 'Unless otherwise indicated, all section references are to the InternalRevenue Code .

Pursuant to section 7463(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 .

Pursuant to section 7463 (b) , the decisions to be entered are not reviewable by any Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and 11 Rule references are to the Tax Court Rules of Practice and rocedure .

Pursuant to section 7463 .(b), the decision to be entered is not reviewable by any other court, and this opinion shall no t .be treated as precedent for any other case .

Pursuant to section 7463 (b) , the decisions to be entered are not reviewable by any Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and 11 Rule references are to the Tax Court Rules of Practice and rocedure .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, an d 'Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

DAWSON, Judge: This case was heard pursuant to the ® provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463 (b), the decision to be entered is not reviewable by any other court, and Unless otherwise indicated, references to sections other than sec.

Pursuant to section 7463 (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.

the provisions of section 7463 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 any ' Unless otherwise indicated , all subsequent section references are to the Internal Revenue CodeSin effect for 2006, the taxable year in issue , and all Rule references are to the Tax Court Rules of Practice and Procedure .

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 Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

LARO, Judge : This case was heard, pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the decision 'Unless otherwise indicated, section references are to the applicable versions of the Internal Revenue Code, and Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463 (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.

.ARMEN, 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 .l Pursuant to section 7463(b), the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(b), the decision to be entered is not.

Pursuant to section 7463(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 .

Pursuant to section 7463(b),' the decision to be entered is not reviewable by any other court, an d 'All section references are the Internal Revenue Code unless otherwise indicated .

ARMEN, 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.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 Internal Revenue Code in effect for the year in issue.

GERBER, Judge : This ;case was heard pursuant to the provisions of section 7463'of the Internal Revenue Code in effec t when the petition was file'd.' Pursuant to section 7463 (b) , th e decision to be entered is,not reviewable by any other court , 'Unless otherwise indicated, .

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 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 7463 (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 .

SERVED Oct 28 2010 - 2 - Pursuant to section 7463 (b), the decision tol be entered in each case is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.

petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue.

CHIECHI, Judge : This case was heard pursuant to the provi`- sions of section 7463-of the Internal Revenue Codeain effect when the petition was filed :' Pursuant to section 7463 (b) , the deci- sion to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(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 .

-Pursuant to section 7463(b),-the decision to be .

Internal Revenue-Code in effect when the petition was filed .' 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.

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

Pursuant to section 7463(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 .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the 'Unless otherwise indicated,jall 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 .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court,-:and 'Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, .

Pursuant to section 7463(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 .

GERBER, Judae : This case was heard pursuant to the provisions of section 7463 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 any other court, and '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 .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 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 an y '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 .

GERBER, Judge : This case was heard pursuant-to the provisions of section 7463 of the Internal Revenue Code in effect, when the petition was filed .' Pursuant to section 7463(b), the '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 .

ARMEN, 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 .1 Pursuant to section 7463(b) , the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2005, the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

CHIECHI, Judge : This case was heard pursuant to the provi- sions of'section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the deci- sion to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

LARO, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any othe r case .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for the years .in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

PANUTHOS, Chief 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 .' 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 (Code) in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

LARO, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, and this opinion shall not be treated as precedent for any other case .

LARO, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, an d .'Unless otherwise indicated, section references are to the applicable versions of the Internal Revenue Code, and Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

ARMEN, 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 .' 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 the taxable year in issue, and all Rule references are to the Tak Court Rules of Practice and Procedure .

THORNTON', Judge: This case was heard pursuant to the provisions of section 7463 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 any other court,, and ' All subsequent section references are to the Internal Revenue Code , as amended .

pursuant to the provisions of-section 7463 of the Internal Revenue Code in effect when the petition was filed in each such case .' Pursuant to section 7463(b), the decisions to be entered 'Hereinafter, all section references are to the Internal Revenue, Code (Code) .

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y ' Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2005, the taxable year at .issue .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 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 any 'Unless otherwise indicated, all section references are to the.-Internal Revenue Code as amended, and all Rule references'are to the Tax Court Rules of Practice and Procedure .

PANUTHOS, Chief Special Trial Judad : These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed .' Pursuant to section 7463(b), the decisions to be entered ' Unless otherwise indicated, all siaction references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

in effect when the petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 1 Unless otherwise indicated,'all subsequent section references are to the Internal Revenue Code in effect for the year in issue .

PANUTHOS, Chief Special Trial Judah : These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed .' Pursuant to section 7463(b), the decisions to be entered ' Unless otherwise indicated, all section references are to the Internal Revenue Code in effect forlthe years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

GALE, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the decisio n 'Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986 as in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

Pursuant to section 7463(b), the decision t o 1 Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

PANUTHOS, Chief 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable; by I p 1 Unless otherwise indicatedl, all section references arei,,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 .

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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all 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 .

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

ARMEN, 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 .' 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,Internal Revenue Code in effect for the year in issue, and all Ruletreferences are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(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 .

Pursuant to section 7463(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.

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y ' Unless otherwise indicated, all ubsequent section references are to the Internal Revenue code in effect for 2005, the taxable year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

LARO, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effec t when the petition was filed .' Pursuant to section 7463 (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 .

Pursuant to section 7463(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 .

GERBER,, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), th e decision to be entered is not" reviewable by any other court, and 'Unless otherwise indicated, all seetion 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 .

PANUTHOS, Chief 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 .1 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 .

GOEKE, Judge : This case is before the Court pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 'Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated .

Pursuant to section 7463(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 .

CARLUZZO, 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 fi(cid:127)led .1 Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant periods .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court , 'Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for period under consideration .

CHIECHI, Judge : This case was heard pursuant to the provi- sions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the deci- sion to be entered is not reviewable by any other court, and thi s .opinion shall not be treated as precedent for any other case .

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered fs not reviewable by any 1 Unless otherwise indicated, .all 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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

ARMEN, Special Trial Judge :, This caste was heard pursuant to the provisions of section 7463 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 an y ' Unless otherwise indicated, all 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 .

ARMEN, 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 .' 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 Internal Revenue'Code in effect for 2005, the taxable year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure..

PANUTHOS, Chief Special Trial Judge : These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed .' Pursuant to section 7463(b), the decision to be entered ' Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, all Rule references are to the Tax Court Rules of Practice an d Procedure, and amounts are rounded .

was heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the decision to be entered is notireviewable by any 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986 (Code), as amended; in effect for the relevant period.

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Petitioners filed the petition in this case pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time that petition wa s SERVED Mar 19 2009 2 - filed.' Pursuant to section 7463(b), the decision to be entere d is'not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(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 .

Pursuant to section 7463(b), .

Pursuant to section 7463(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 .

PANUTHOS, Chief Special Trial Judae : This case was heard pursuant to the provisions of section 7463 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, section references are to the Internal .

Pursuant to section 7463(b), the decision to be entered is not revieable by any other court, and this opinion shall not be treated a precedent for any other case .

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

LARO, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when th e petition was filed .' Pursuant to section 7463(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 .

GOLDBERG, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code : in effect at the .time the petition was filed., Pursuant to section 7463 (b), the decision to be entered is not reviewable by an y other court, and this opinion shall not be treated as preceden t for any other case .

Revenue Code in effect when the petition was filed.' Pursuant to section 7463(b), the decision to be entered is not reviewable by any '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 7463(b), the decision to 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for' the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

PANUTHOS, Chief Special Trial Judge : These consolidated cases were heard pursuant to the provisions of section 7463 o f the Internal Revenue Code in effect when the petitions were 4 OERVED JUL 1 32009 2 - filed .' Pursuant to section 7463(b), the decision to be entered in each docket is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(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 the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .l Pursuant to section 7463(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 'Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for the tax year at issue .

PANUTHOS, Chief Special Trial Judge : These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed .' Pursuant to section 7463(b), the decision to be entered ' Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, all Rule references are to the Tax Court Rules of Practice an d Procedure, and amounts are rounded .

CARLUZZO, Special Trial Judge : This case was-heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 'Section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period .

Pursuant to section 7463(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 .

heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the decision to be entered is-not reviewable by-an y 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended , in effect for the 'relevant period .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to Section 7463(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 .

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court , 'Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 2005, the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

ARMEN, Special Trial Judge : This Lase was heard pursuant to the provisions of section 7463 of the I~'ternal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the decision to be entered is rot reviewable by an y ' Unless otherwise indicated, all 'subsequent section references are to the Internal Revenue Code in effect for th e taxable years in issue .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

' Pursuant to section 7463(b), the decisions to be entere d 'Hereinafter, all section references are to the Internal Revenue Code (Code) in effect for the years at issue .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

ARMEN, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed .' 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 Internal Revenue Code in effect for 2004, the taxable year in issue .

GALE, Judge : This- case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b),the decisio n 'Unless otherwise indicated , all section references are to the Internal Revenue Code of 1986 as in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

at the time that the petition was filed .' Pursuant to section 7463(b), the decision to be ent red is not reviewable by ' Unless otherwise indicated, all subsequent section references are to the Internal Revenue ;ode in effect for 2003, the taxable year in issue, and all Rule references are to the Ta x Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

LARO, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, and this opinion shall not be treated as precedent for any other case .

CHIECHI, Judge :- This case was heard' pursuant to the provi- sions of section 7463 of-the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463 ( b) ; the deci- sion to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

CARLUZZO, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period .

Pursuant to section 7463(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.

Pursuant to section 7463 (b), the-decision to-be entered is not reviewable by any other court , and this opinion shall not(cid:127)'be treated as precedent for any other case ., Unless otherwise indicated, .

Pursuant to section 7463(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 .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), th e decision to be entered is not reviewable by any other court, an d 'Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure .

CHIECHI, Jude : This case was heard pursuant to the provi- sions of section 7463 of the'Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the deci- sion to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(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 .

WELLS, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y '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 7463 (b), the decision to be entered .

PANUTHOS, Chief 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 .' Pursuant to section 7463(b) ; the decision to be entered is not reviewable b y ' 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 .

PANUTHOS, Chief 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..' Pursuant to section 7463(b), the decision to be entered is not reviewable b y 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for.

PANUTHOS, Chief Special Trial Judge : These consolidated cases were heard pursuant to the provisions of section 7463 o f the Internal Revenue Code in effect when the petitions were 4 OERVED JUL 1 32009 2 - filed .' Pursuant to section 7463(b), the decision to be entered in each docket is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

to the provisions of section 7463 of the Internal Revenue Code -ineffect when the petition was filed .' Pursuant to section 7463(b), the decision to be entered-is not reviewable by any other court, and 'Section references are to the applicable versions of the, Internal Revenue Code .

ARMEN, Special Trial Judge : This case(cid:127)was heard pursuant to the provisions of section 7463 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 an y 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

CHABOT, Judge : This case was heard pursuant to section 7463 .1 The decision to be entered is not reviewable by any other .court, and this opinion shall not be treated as a precedent for any other case .

Pursuant to section 7463(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 SERVED Sep 22 2009 r 2 case .

Pursuant to section 7463(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 .

PANUTHOS, Chief 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.' Pursuant to section 7463(b), the decision to be entered is not reviewable by 1 Unless otherwise indicated, section references are to the .

Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court , SERVED Apr 30 2009 and this opinion shall not be treated as precedent for any other case .' Respondent determined a Federal income tax deficiency of $2,695 for 2004 .

Pursuant to section 7463(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 .

case was heard pursuant to the provisions of section 7463 of the Internal Revenue-Code in effect at the time the petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Park, for respondent ., LARO, Judge: This case was heard pursuant to the provisions of section 7463 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 any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(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 .

CARLUZZO, 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 'Unless otherwise indicated, section references ate to the Internal Revenue Code of 1986, as amended, in effect for the year in issue .

Pursuant to section 7463(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 .

CHIECHI, Judge : This case was heard pursuant to the provi- sions of section 7463 of the Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(b), the deci sion to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

Pursuant to section 7463(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 .

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

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

Pursuant to section 7463(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 .

CARLUZZO, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 'Unless otherwise indicated, section references are to the Internal Revenue 'Code of 1986, as amended, in effect for the year at issue ., Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(b), the decision to be entered is not reviewable by any .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not b e 'Cases of the following petitioners are consolidated herewith : Timothy A .

GOLDBERG , 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 .' Pursuant to section 7463 (b), the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

SERVED Aug 25 2008 when the petitions were fi-led..2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court , and"this"'"opinion shall not be treated as precedent for any other Petitioner sought relief from joint and several tax liability'for 1994, 1995, and 1996 .

HAINES, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463 (b), the by decision to be entered is not reviewable any other court, and 'Unless otherwise indicated, section references are to the Internal Revenue Code, as amended, and as , in effect when the petition was filed .

Pursuant to section 7463(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 .

CARLUZZO, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any 1 Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, an d ' Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 2003, the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

NIMS, Judge : This case was healyd pursuant to the provisions of section 7463 of the Internal Revelnue Code in effect when the petition was filed : Pursuant to section 7463(b), the decision t o be entered is not reviewable by any other court, and this opinio n shall not be treated as precedent fdr any other case .

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

Pursuant to section 7463(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 .

ARMEN, 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 .' Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by any 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2004, the taxable year .at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(b), the decisi n to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case Unless otherwise SERVED FEB 2 8 2008 - 2 - indicated, subsequent section references are to the Internal Revenue Code, and all Rule references are to the Tax Co

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

THORNTON , Judge : This case was heard .pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463 (b), the decision to be entered is not reviewabl e by any other court, and 1 Unless .otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended and in effect for the year at issue , and Rule references are to the Tax Court Rules of Practice and Procedure .

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

Pursuant to section 7463(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 .

VASQUEZ, Judge : This case was-heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.' Pursuant to section 7463(b), the decision.

GOLDBERG, Special Trial Judge : This case was heard pursuant to section 7463 of the Internal Revenue Code in effect at the time the petition was filed .

Pursuant to section 7463 (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 .

RUWE,' Judge : This case was heard pursuant to the provision s of section 7463 of the Intertlal .Re'enue Code in effect when th e petition was filed .' Pursuant to section 7463(b), the decisio n to be entered is not reviewa)le,by any other court, and thi s opinion shall not be treated as precedent for any other case .

Pursuant to section 7463 ( 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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

ARMEN, 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 .' 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 Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

CARLUZZO, Special Trial Judge : This case was heard pursuant to the provisions of section 7463 .1 Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 1 Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period .

Pursuant to section 7463(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 .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

HAINES, Judge : These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed .' Pursuant to section 7463(b), the decisions to be entered are not reviewable by any 'Unless otherwise indicated, all section references are to the Internal Revenue Code (Code), as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure .

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

WHERRY, Judge : This case was heard 1 pursuant to the provisions of section 7463 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 any other court, and 'Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as ineffect for the year in issue, and all Rule references are to th$ Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

DAWSON, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the ' Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended and in effect for the year at issue, and Rule references are to the Tax Court Rules of Practice and Procedure .

SERVED Aug 25 2008 when the petitions were fi-led..2 Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court , and"this"'"opinion shall not be treated as precedent for any other Petitioner sought relief from joint and several tax liability'for 1994, 1995, and 1996 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

ARMEN, 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 .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y 1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

when the petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and references 1 Unless otherwise indicated, section are to the Internal Revenue.

WHERRY, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, and 'Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

VASQUEZ, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, and ' 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 .

VASQUEZ, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and 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 7463(b), the decision to be entered is not reviewable by any other court , 'Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 2005, the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

RUWE, Judge : This case was brought pursuant to the provisions of section 7463 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 any other court, an d ' Unless otherwise indicated, all section references are to the Internal Revenue Code as amended .

GOEKE, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed .' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y I Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 7463.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any 1 Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period.

Pursuant to section 7463(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 the provisions of section 7463 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 any other court, and 'Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure .

THORNTON, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, and 1 Unless'otherwise indicated,' section references are to the Internal Revenue Code of 1986, in effect for the year in issue .

GOEKE, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, and 'Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

'Pursuant to section 7463 (b) Unless otherwise indicated, all section references are to the Internal Revenue ode in effect for 2003, the taxable year,i issue, and all Rule references are to the Tax Court Rules o f Practice and Procedur SERVED OCT 2 8.2008 4 2 the decision to be entered is not reviewable by any other court,

ARMEN, 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.' Pursuant to section 7463(b), the decision to be entered is not reviewable by an y ' Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2004, the taxable year at issue .

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

Pursuant to section 7463(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 .

GERBER, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was-filed .' Pursuant to section 7463(b), the decision to be entered is not revie able by any other court, and 1 Unless otherwise indicated, a 1 section references are to the Internal Revenue Code in ffect for 2004, the taxable year in issue, and all Rule reference are to the Tax Court Rules of Practice and Procedure .

WELLS, Judge : This case was heard pursuant-to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed .' Pursuant to section 7463(b), the-decision to be entered is not reviewable by any 'All section references are to the Internal Revenue Code in effect for the year in issue .

JACOBS, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed .' Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

VASQUEZ, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and 1 Unless otherwise indicated, all 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.

Pursuant to section 7463 (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 .

WELLS, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the 'Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all subsequent section references are to the Internal Revenue Code as in effect for the years in issue .

Pursuant to section 7463(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 .

Pursuant to section 7463(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 .

VASQUEZ, Judge : This case was heard pursuant to the provisions of section 7463 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 any other court, and 1 Unless otherwise indicated, all 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 .

Pursuant to section 7463(b),' the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any othe r 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue .

Pursuant to section 7463(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 .

Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this opinion shall not be treated as precedent for any other case .

THORNTON, Judge : This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed .' Pursuant to section 7463(b), the ' Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, in effect for the year in issue .

RUWE, Judge : This case was brought pursuant to th e provisions of section 7463 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 any other court, and this opinion shall not be treated as precedent for any othe r ' Unless otherwise indicated, all section .

Pursuant to section 7463(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 .

HAINES, Judge : These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed .' Pursuant to section 7463(b), the decisions to be entered are not reviewable by any 'Unless otherwise indicated, all section references are to the Internal Revenue Code (Code), as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Pursuant to section 7463(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 .

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

Pursuant to section 7463(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 7463 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 opinion shall not be treated as precedent for any other case .