Scott Williams Smith and Virginia May Smith, (2009)

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Scott Williams Smith and Virginia May Smith, (2009)

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.

T.C. Summary Opinion 2009-52

UNITED STATES TAX COURT SCOTT WILLIAMS SMITH AND VIRGINIA MAY SMITH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4616-08S. Filed April 15, 2009.

Scott Williams Smith and Virginia May Smith, pro sese. A. Gary Begun, for respondent.

CHIECHI, Judge: This case is before the Court on respondent's motion for summary judgment (respondent's motion). We shall grant respondent's motion. Petitioners filed the petition in this case pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at that time.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.

Background Many of the facts are deemed established pursuant to Rule 90(c). The record establishes and/or the parties do not dispute other facts.

Petitioners resided in Michigan at the time they filed the petition in this case.

During 2005, the year at issue, petitioner Virginia May Smith (Ms. Smith) worked for the o...

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