§74631

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

We hold that they are not.

PARIS, Judge : This case was heard pursuant to section 74631 of the Internal Revenue Code in effect when the petition was filed .

FOLEY, Judge : This case was heard pursuant to section 74631 of the Internal Revenue Code .

FOLEY, Judge : This case was heard pursuant to section 74631 of the Internal Revenue Code .

RUWE, Judge : This case was heard pursuant to section 74631 in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to section 74631 in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to section 74631 in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to section 74631 in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to section 74631 in effect when the petition was filed .

POWELL, Special Trial Judge: This case was heard pursuant to section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

COUVILLION, Special Trial Judge: This case was heard pursuant to section 74631 in effect at the time the petition was filed.

COUVILLION, Special Trial Judge: This case was heard pursuant to section 74631 in effect at the time the petition was filed.

COUVILLION, Special Trial Judge: This case was heard pursuant to section 74631 in effect at the time the petition was filed.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION FRIED, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION FUNG, Judge: This case was brought pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION WAY, Judge: This case was brought pursuant to the provisions of section 74631 in effect when the Petition was filed.

SUMMARY OPINION PARIS, Judge: This case was brought pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION SIEGEL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION FRIED, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION SIEGEL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION SIEGEL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION LAUBER, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION LANDY, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION ARBEIT, Judge: This case was brought pursuant to the provisions of section 74631 in effect when the petition was filed.

SUMMARY OPINION FRIED, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION SIEGEL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION COPELAND, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION PUGH, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION LANDY, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION LANDY, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION SIEGEL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION FRIED, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION WEILER, Judge: This case was brought pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION PARIS, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

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

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION WEILER, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION WEILER, Judge: This case was brought pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the Petition was filed.

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

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

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the 1Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended and in effect for the relevant period.

SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the 1Unless otherwise indicated, section references are to the Internal Revenue (continued...) Served 05/19/21 - 2 - petition was filed.

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

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

SUMMARY OPINION COLVIN, Judge: This case was heard pursuant to the provisions of section 74631 of the Code in effect when the petition was filed.

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

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

SUMMARY OPINION RUWE, Aldge: The petition in this case was filed pursuantto the provisions ofsection 74631 ofthe Internal Revenue Code.

SUMMARY OPINION GOEKE, Judae: This case was heard pursuant to the provisions ofsection 74631 in effect whenthe petition was filed.

SUMMARY OPINION RUWE, Judge: This case was heard pursuant to the provisions ofsection 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 74631 ofthe Internal Revenue Code in effect when the 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the years in issue.

SUMMARY OPINION RUWE, Judge: The petition in this case was filed pursuant to the provisions ofsection 74631 ofthe Internal Revenue Code.

SUMMARlY OPINION CARLUZZO, Special Trial Judge This case was heard pursuant to the provisions ofsection 74631 ofthe Internal Revenue Code in effect when the IUnless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for he year in issue.

SUMMARY OPINION RUWE, Judae: The petition in this case was filed pursuantto the provisions ofsection 74631 ofthe Internal Revenue Code.

SUMMARY OPINION CARLUZZO, Special Trial Judge: This case was heard pursuant to the provisions ofsection 74631 ofthe Internal Revenue Code in effect when the 1Section references other than to sec.

SUMMARY OPINION RUWE, Judge: This case was heard pursuantto the provisions ofsection 74631 ofthe Internal Revenue Code in effect when the petition was filed.

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

SUMMARY OPINION RUWE, Judge: The petition in this case was filed pursuantto the provisions ofsection 74631 ofthe Internal Revenue Code.

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

SUMMARY OPINION GOEKE, Judge: This case was heard pursuant to the provisions ofsection 74631 ofthe Internal Revenue Code.

SUMMARY OPINION GOEKE, Judge: This case was heard pursuantto the provisions ofsection 74631 ofthe Internal Revenue Code.

SUMNIARY OPINION KROUPA, Judge: This case was heard pursuant to tl e provisions ofsection 74631 ofthe Internal Revenue Code in effect when the peti ion was filed.

SUMMARYOPINION MARVEL, Judge: This case was heard pursuant to the provisions ofsection 74631 ofthe Internal Revenue Code in effect when the petition was filed.

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

SUMMARY OPINION GOEKE, Judge: This casb was heard pursuant to the provisions ofsection 74631 ofthe Internal Revenue Code in effect when the petition was filed.

SUMMARYOPINION RUWE, Judge: This case was heard pursuant to the provisions ofsection 74631 ofthe Internal Revenue Code in effect when the petition was filed.

SUMMARY OPINION GOEKE, Judae: This case was heard pursuant to the provisions ofsection 74631 ofthe Internal Revenue Code in effect when the petition was filed.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internäl Revenue Code in- effect when the petition was filed.

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

i GERBER, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

GUSTAFSON, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

KROUPA, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge:, This case was heard pursuant to the provisions, of section 74631 of the Internal Revenue Code in effect when the petition was filed.

KROUPA, Judge: This case was heard pursuant to the - provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

MARVEL, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

HAINES, Judge : This case was heard pursuant to the provisions of section 74631of 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 Internal Revenue Code, as amended .

KROUPA, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the'petition was filed.

RUWE, Judge : This case was brought pursuant to the provisions of section 74631 of~the Internal Revenue Code in effect when the petition was filed .

WELLS, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in' effect when the petition was filed .

RUWE, judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge: The petition in this case was filed pursuant to the provisions of section 74631 of the Internal Revenue Code.

KROUPA, Judge : This .case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

was heard pursuant to the provision s of section 74631 of the Internal Revenue Cod e in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge : This case .was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

DAWSON, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code-ini effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

section 74631 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 no t .be treated as precedent for any other case . 'Subsequent section references are to the Internal Revenue Code of 1986, as amended and in effect

RUWE, Judge : -This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal" Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to-the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

KROUPA, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

GUSTAFSON, Judge : This case was heard pursuant to the provisions of section 74631 in effect when the petition was, filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the .petition was filed .

KROUPA, Judge : This case=was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed .

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

GUSTAFSON, Judge : This case was heard pursuant to the provisions of section 74631 in effect when the petition was filed .

GOEKE, Judge: This case is before the Court pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed .

VASQUEZ, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was brought pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

provisions of, section 74631 of the - InternalRevenue Code ~in effect when the petition was filed.

VASQUEZ, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in' effect when th e petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

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

GUSTAFSON, Judge : This case was heard pursuant to the provisions of section 74631 in effect when the petition was filed .

PARIS, Judge : This case was heard ursuant to the provisions of section 74631 of the Intern 1 Revenue Code i n effect at the time the petition was file .

RUWE, Judge : These consolidated-cases were heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petitions were filed .

GERBER, Judge : This case was heard pursuant to the provisions of section 74631 of the Intern 1 Revenue Code in effect when the petition was filed .

GUSTAFSON, Judge : This case was heard pursuant to the provisions of section 74631 in effect when the petition was filed .

RUWE, Judge : These consolidated-cases were heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petitions were filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

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

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

WELLS, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed .

was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed .

provisions of section 74631 of the Internal Revenue Code in effect when-the petition was filed.

VASQUEZ, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was'fi;led .

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

WELLS, Judge; This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code i n effect at the time the petition was filed.

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

VASQU.EZ, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect'when the petition was filed..

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

GOEKE, Jud e : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed .

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

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

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

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

VASQUEZ, Judae : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

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

KROUPA, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the :time the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

WELLS, Judge : The instant case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

FOLEY, Judge : This case was heard ursuant to the provisions of section 74631 of the Inter' al Revenue Code i n effect when the petition was filed .

FOLEY, Judge : This case was heard pursua t to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

FOLEY, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed.

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

GOEKE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

KROUPA, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

FOLEY, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

GOEKE , Judge : This case was heard pursuant to the provisions of section 74631 in effect at the time the petitio n '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 Ru es of Practice and Procedure .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

KROUPA, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed .

FOLEY, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

RUWE, Judge : This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed .

KROUPA, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed .

GALE, Judge: This case was heard pursuant to the provisions of section 74631 providing for small tax case proceedings.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

KROUPA, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

FOLEY, Judge : This case was heard pub suant to the provisions of section 74631 of the Internal,' Revenue Code in effect when the petition was filed .

KROUPA, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time of trial.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

KROUPA, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

GALE, Judge: This case was heard pursuant to the provisions of section 74631 providing for small tax case proceedings.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

COLVIN, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

KROUPA, Judge: This case was heard pursuant to the provisions of section 74631 in effect at the time the petition in this case was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

VASQUEZ, Judge: This case was heard pursuant to the provisions of section 74631 in effect at the time petitioner filed the petition.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

VASQUEZ, Judge: This case was heard pursuant to the provisions of section 74631 in effect at the time petitioners filed the petition.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code 1 Unless otherwise indicated, subsequent section references are to the Internal Revenue Code for the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.

RUWE, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.

POWELL, Special Trial Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect at the time the petition was filed.