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PRUITT v. COMMISSIONER

Docket Nos. 12863-90, 21986-90.

63 T.C.M. 2628 (1992)

T.C. Memo. 1992-194

Charlie David Pruitt and Clarice Pruitt v. Commissioner.

United States Tax Court.

Filed March 31, 1992.

Attorney(s) appearing for the Case

Charlie David Pruitt and Clarice Pruitt, pro se. Scott D. Anderson, for the respondent.

Memorandum Opinion

DINAN, Special Trial Judge:

This case is before us on petitioners' motion for reconsideration of our opinion, T.C. Memo. 1991-398. In that opinion, we addressed our attention, in accordance with arguments of the parties, to the issue of whether the notice of deficiency for the year 1985, in docket No. 21986-90, was timely. We held that it was timely issued.

Petitioners' motion for reconsideration...

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