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HUDSON v. COMMISSIONER

Docket No. 4272-92.

100 T.C. 590 (1993)

JAMES L. HUDSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 23, 1993.

Attorney(s) appearing for the Case

James L. Hudson, pro se.1

T. Richard Sealy, III, for respondent.

OPINION

SWIFT, Judge:

After trial on March 5, 1993, the parties were asked by the Court to submit briefs on one of the primary legal arguments made by petitioner herein; namely, whether respondent is barred by collateral estoppel from contesting the value of certain master educational audio tapes (master audio tapes) as found by a Federal District Court in an injunction proceeding under sections 6700 and 7408.

Respondent determined deficiencies...

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