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DELEET MERCHANDISING CORP. v. COMMISSIONER

Docket No. 3220-80.

44 T.C.M. 44 (1982)

T.C. Memo. 1982-310

Deleet Merchandising Corp. v. Commissioner.

United States Tax Court.

Filed June 7, 1982.

Attorney(s) appearing for the Case

Leonard A. Messinger, 655 Madison Ave., New York, N.Y., for the petitioner. Richard J. Sapinski, for the respondent.

Memorandum Opinion

SHIELDS, Judge:

This case is before the Court on petitioner's motion for partial summary judgment1 under Rule 121.2 The question to be decided is whether or not respondent's deficiency notice was timely mailed within the period prescribed by section 6501(a)3 with respect to the years 1966 to 1969.

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