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JEFFREY S. v. COMMISSIONER

Docket No. 3716-00L.

83 T.C.M. 1268 (2002)

T.C. Memo. 2002-53

Jeffrey S. and Susan L. Duffield v. Commissioner.

United States Tax Court.

Filed February 25, 2002.

Attorney(s) appearing for the Case

Joyce Griggs, Cincinatti, Ohio, for the petitioners.

Ross M. Greenberg and Joanne B. Minsky, for the respondent.

MEMORANDUM OPINION

FOLEY, Judge:

The issues in this case are whether respondent has met the requirements of section 63301 and whether petitioners are liable for the section 6673(a)(1) penalty.

Background

Jeffrey and Susan Duffield resided in Bear, Delaware, when they filed their petition. The assessments relate to liabilities that petitioners reported on 1988, 1989, 1990, 1992, 1993, 1995, and 1996 Federal...

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