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WEBSTER v. COMMISSIONER

Docket No. 21491-91.

64 T.C.M. 724 (1992)

T.C. Memo. 1992-538

G. Marshall Webster and Lisa R. Herlach v. Commissioner.

United States Tax Court.

Filed September 14, 1992.

Attorney(s) appearing for the Case

James J. Everett, 3101 N. Central Ave., Phoenix, Ariz., for the petitioners. Rachael J. Zepeda, for the respondent.

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case was considered pursuant to section 7443(A)(b)(3) and Rules 180, 181, and 182,1 and is before the Court on petitioners' motion for an order enjoining respondent from collection activities.

Respondent determined additions to tax for petitioner G. Marshall Webster for tax years 1983 and 1984, and for petitioners G. Marshall Webster and Lisa R. Herlach filing jointly...

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