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GILMORE v. COMMISSIONER

Docket No. 13358-88.

58 T.C.M. 739 (1989)

T.C. Memo. 1989-626

Paul J. Gilmore v. Commissioner.

United States Tax Court.

Filed November 21, 1989.

Attorney(s) appearing for the Case

Victor Chini, 915 State Tower Bldg., Syracuse, N.Y., for the petitioner. John D. Steele, Jr., for the respondent.

Memorandum Opinion

PETERSON, Chief Special Trial Judge:1

Respondent issued a notice of deficiency on April 4, 1988, for the taxable year 1983. A petition was filed on June 13, 1988. In the petition it was alleged that the notice of deficiency was issued in error since petitioners had settled their tax dispute with respondent at the audit level and paid the tax, additions to tax, and interest. Petitioner also alleged in his petition...

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