SNEED, Circuit Judge:
The Commissioner of Internal Revenue (the Commissioner) determined deficiencies in the income taxes of Schwartz Farms, Inc. (Schwartz Farms), a dissolved corporation. The Commissioner further asserted that Schwartz Farms' primary shareholders, Dorothy Schwartz Rojas and her deceased husband's estate (collectively referred to as "the taxpayer"), were liable for the alleged deficiencies. The taxpayer petitioned the Tax Court for a review of the...
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