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PAUL v. COMMISSIONER

Docket No. 20773-82.

49 T.C.M. 517 (1985)

T.C. Memo. 1985-21

Lawrence M. Paul and Isabelle Paul v. Commissioner.

United States Tax Court.

Filed January 14, 1985.

Attorney(s) appearing for the Case

K. G. Seitz, 4321 Hamilton Ave., Cincinnati, Ohio, for the petitioners.

Genevieve K. Murtaugh and Keith A. Aqui, for the respondent.

Memorandum Opinion

CANTREL, Special Trial Judge:

This case came before the Court for hearing, consideration and ruling on respondent's motion for partial summary judgment filed on December 17, 1982.1 In his motion, respondent seeks a ruling that the notice of deficiency is valid.

The material facts are not disputed. On June 11, 1982 respondent, by certified mail, sent...

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