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

1Section references are to the Internal Revenue Code of
1986, as amended, in effect for the relevant period. Rule
references are to the Tax Court Rules of Practice and Procedure.

T.C. Summary Opinion 2009-49

UNITED STATES TAX COURT

KULVINDER S. BOPARAI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent

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