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MALONEY v. COMMISSIONER

Docket No. 17617-80.

51 T.C.M. 572 (1986)

T.C. Memo. 1986-91

Patrick J. Maloney v. Commissioner.

United States Tax Court.

Filed March 10, 1986.

Attorney(s) appearing for the Case

Cyril L. Lawrence, 555 West 26th St., Merced, Calif., for the petitioner. Bryce Kranzthor, for the respondent.

PARR, Judge:*

Respondent determined a deficiency in petitioner's 1976 Federal income tax in the amount of $184,655.

This case involves the validity of respondent's notice of deficiency. Specifically, the issues presented for decision are (1) whether petitioner's 1976 tax year was closed, so as to prevent respondent from determining further deficiencies; (2) whether respondent failed to...

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