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WAGNER v. COMMISSIONER

Docket No. 7186-00L.

118 T.C. 330 (2002)

118 T.C. No. 18

RICHARD T. WAGNER AND MARGIE WAGNER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 15, 2002.

Attorney(s) appearing for the Case

Keith H. Johnson, for petitioners.

William R. McCants, for respondent.

OPINION

LARO, Judge:

Petitioners petitioned the Court under section 6320(c) to review a notice of a Federal tax lien placed upon their property. The lien arose from an assessment of Federal income taxes of $412,787.15 and $844.16 for 1991 and 1996, respectively. Petitioners now, after being served with respondent's answer and respondent's motion for summary judgment, move the Court to dismiss this case without prejudice to their right to seek in Federal...

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