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STINNETT v. COMMISSIONER

Docket No. 30047-89.

66 T.C.M. 750 (1993)

T.C. Memo. 1993-429

William R. Stinnett and Lavonne C. Stinnett v. Commissioner.

United States Tax Court.

Filed September 15, 1993.

Attorney(s) appearing for the Case

Herald J.A. Alexander and Patsy A. Austin, for the petitioners. Sergio Garcia-Pages and Jordan S. Musen, for the respondent.

Memorandum Opinion

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on respondent's motion for partial summary judgment and petitioners' motion to dismiss for lack of jurisdiction. The issue common to both motions concerns the validity of the deficiency notice issued in this case and the question of whether respondent "determined" a deficiency in petitioners' Federal income tax liability within the meaning of section 6212(a).

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