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BARTON v. COMMISSIONER

Docket No. 3438-91.

97 T.C. 548 (1991)

ANDREW P. BARTON, JR. AND ANN BARTON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 18, 1991.

Attorney(s) appearing for the Case

Thomas C. Rink, for the petitioners.

John J. Boyle, for the respondent.

OPINION

RUWE, Judge:

This matter is before the Court on petitioners' motion to reconsider the granting of respondent's motion to dismiss and to strike. The issue for decision is whether this Court has jurisdiction to determine the propriety of respondent's assessment of increased interest under section 6621(c) when a taxpayer alleges that there has been an overpayment as a result of paying such increased interest...

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