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KLUGER v. COMMISSIONER

Docket No. 26124-83.

83 T.C. 309 (1984)

DEBRA KLUGER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 11, 1984.

Attorney(s) appearing for the Case

Elliot Silverman and Robert S. Fink, for the petitioner.

Sergio Garcia-Pages, for the respondent.

KÖRNER, Judge:

This case is before us on petitioner's motion to suppress evidence and to shift the burden of proof, treated as a motion to shift the burden of going forward with the evidence, to respondent.1 Respondent determined a deficiency of $769,769.34 in petitioner's 1979 Federal income tax. Respondent's statutory notice of deficiency which contained this determination was based solely upon information respondent secured...

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