POWELL v. COMMISSIONER

Docket Nos. 19726-90, 19727-90.

96 T.C. 707 (1991)

THOMAS C. POWELL AND JOYCE R. POWELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 20, 1991.


Attorney(s) appearing for the Case

Thomas C. Powell and Joyce R. Powell, pro se.

Marsha Keyes, for the respondent.


OPINION

NIMS, Chief Judge:

These cases are before the Court on petitioners' motions to restrain assessment and collection. (Unless otherwise indicated, all section references are to sections of the Internal Revenue Code as in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure.)

Background

On November 9, 1988, respondent issued notices of final partnership administrative adjustment...

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