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EDWARDS v. COMMISSIONER

Docket No. 257-98.

77 T.C.M. 1446 (1999)

T.C. Memo. 1999-52

Kenneth E. and Lois M. Edwards v. Commissioner.

United States Tax Court.

Filed February 25, 1999.

Attorney(s) appearing for the Case

Kenneth E. and Lois M. Edwards, pro sese. Jeremy L. McPherson, for the respondent.

MEMORANDUM OPINION

GERBER, Judge:

Respondent determined a deficiency in petitioners' 1993 Federal income tax in the amount of $83,430 and a penalty under section 6662(a)1 in the amount of $16,686. The issue for our consideration is whether, as petitioners contend, respondent's determination of a deficiency is procedurally flawed.

Petitioners believe that respondent's issuance of their deficiency notice was an improper...

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