Villela-Wilcox v. Commissioner of Internal Revenue

PURSUANT TO INTERNAL REVENUE CODE
SECTION 7463(b),THIS OPINION MAY NOT
BE TREATED AS PRECEDENT FOR ANY
OTHER CASE.
1

Unless otherwise noted, section 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 2009-75

UNITED STATES TAX COURT

LILLIAN DOREEN VILLELA-WILCOX, Petitioner, AND
DAVID […]