Your search Notice: This Summary Order May Not Be Cited As Precedential Authority, but May Be Called to the Attention of the Court in a Subsequent Stage of This Case, in a Related Case, or in Any Case for Purposes of Collateral Estoppel or Res Judicata. See Second Circuit Rule 0.23.paul C. Matthews, and Vera C. Matthews, Petitioners-appellants, v. Commissioner of Internal Revenue, Respondent-appellee did not match any document.