JENKINS v. COMMISSIONER

Docket No. 14383-93.

102 T.C. 550 (1994)

JOHN P. JENKINS AND DEBRA R. LAPPIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 6, 1994.


Attorney(s) appearing for the Case

John G. Brant, for petitioners.

David P. Monson, for respondent.


OPINION

GERBER, Judge:

Petitioners notified respondent that they reported an item inconsistently from a partnership within the meaning of section 6222.1 Respondent issued a notice of deficiency to petitioners and disallowed the allegedly inconsistent position. Petitioners filed a petition and then a motion to dismiss, contending2 that the deficiency...

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