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ANDERTEN v. COMMISSIONER

Docket No. 3001-92.

65 T.C.M. 1697 (1993)

T.C. Memo. 1993-2

Thomas J. Anderten v. Commissioner.

United States Tax Court.

Filed January 4, 1993.

Attorney(s) appearing for the Case

Larry V. Bishins, 4548 N. Federal Hwy., Fort Lauderdale, Fla., for the petitioner. Alison W. Lehr, for the respondent.

Memorandum Opinion

PANUTHOS, Chief Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181 and 183.1 This matter is before the Court on petitioner's motion to dismiss or, in the alternative, to shift the burden of proof. The issue for decision is whether the notice of deficiency is invalid or otherwise defective.

In a notice of deficiency issued December 10, 1991,...

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