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HUGHEY v. COMMISSIONER

Docket No. 14230-92.

67 T.C.M. 2440 (1994)

T.C. Memo. 1994-116

Norman D. Hughey v. Commissioner.

United States Tax Court.

Filed March 22, 1994.

Attorney(s) appearing for the Case

Norman D. Hughey, pro se. Dale A. Zusi, for the respondent.

Memorandum Opinion

HAMBLEN, Chief Judge.

This matter is before the Court on respondent's motion for summary judgment filed under Rule 121.1 The issues respondent seeks to have adjudicated are:

(1) Whether respondent is precluded from assessing and collecting any of petitioner's alleged tax deficiencies and additions to tax due to the expiration of the 3-year limitations period on assessments and collections provided by...

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