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ROSZKOS v. COMMISSIONER

Docket No. 45403-85.

87 T.C. 1255 (1986)

LOUIS E. ROSZKOS AND VIVIAN L. ROSZKOS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 4, 1986.

Attorney(s) appearing for the Case

Woodford G. Rowland, for the petitioners.

Thomas M. Rohall, for the respondent.

GERBER, Judge:

Respondent, in a notice of deficiency dated October 28, 1985, determined deficiencies in petitioners' 1973 and 1974 Federal income taxes in the amounts of $33,178 and $36,136, respectively. Petitioners filed a timely petition reflecting a legal residence of Alamo, California. Petitioners, on January 21, 1986, moved to dismiss for lack of jurisdiction on the ground that respondent's October 28, 1985,...

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