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KOVENS v. COMMISSIONER

Docket No. 5435-82.

91 T.C. 74 (1988)

CALVIN KOVENS AND ROZ M. KOVENS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 20, 1988.

Attorney(s) appearing for the Case

Harvey M. Silets, Steven S. Brown, and Royal B. Martin, Jr., for the petitioners.

Thomas R. Ascher, for the respondent.

OPINION

GERBER, Judge:

Petitioners, by a motion dated April 6, 1988, seek an interlocutory appeal pursuant to section 7482(a)(2) and Rule 193.1 In a recent opinion (Kovens v. Commissioner, 90 T.C. 452 (1988)), we denied petitioners' motion to dismiss for lack of jurisdiction. In that motion, petitioners maintained that respondent's notice of deficiency was untimely. Petitioners argued...

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