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MARKS v. C.I.R.

No. 90-1036.

947 F.2d 983 (1991)

Harold J. MARKS, a/k/a Haley Justin Van De Mark and Lea Marks, a/k/a Alanna Leigh Van De Mark, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided October 29, 1991.

Attorney(s) appearing for the Case

Robert L. Shevin, Miami, Fla., for appellants.

Gilbert S. Rothenberg, Atty., Dept. of Justice, with whom Shirley D. Peterson, Asst. Atty. Gen., and Gary R. Allen, Atty., Dept. of Justice, Washington, D.C., were on the brief, for appellee.

Before EDWARDS and SILBERMAN, Circuit Judges, and VAN GRAAFEILAND, Senior Circuit Judge, United States Court of Appeals for the Second Circuit.

Opinion for the Court filed PER CURIAM.

PER CURIAM:

Appellants Harold J. and Lea Marks (a/k/a Haley Justin and Alanna Leigh Van De Mark) were involved in the organization and promotion of tax shelters from 1973 to 1979, which led eventually to criminal and civil tax investigations. On June 30, 1982, pursuant to 26 U.S.C. § 6212, the Commissioner of Internal Revenue (Commissioner) sent, by certified mail, duplicate notices of deficiency — involving...

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