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MONAHAN v. C.I.R.

No. 02-12164 Non-Argument Calendar.

321 F.3d 1063 (2003)

Rosalie MONAHAN, individually and in her capacity as executrix of the estate of Dean R. Monahan, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

February 13, 2003.

Attorney(s) appearing for the Case

Tobias Weiss, Stamford, CT, for Petitioner-Appellant.

David E. Carmack, John A. Nolet, Appellate Section, Washington, DC, for Respondent-Appellee.

Before ANDERSON, BLACK and MARCUS, Circuit Judges.

ANDERSON, Circuit Judge:

Petitioner, Rosalie Monahan, on behalf of herself and as executrix of her husband's estate, appeals from a judgment of the United States Tax Court denying their petition for a redetermination of tax deficiency.1 Mr. and Mrs. Monahan (hereinafter "Taxpayers") received a notice of tax deficiency in May of 1996 indicating that they owed penalties and interest stemming from an underpayment of taxes in 1982. Taxpayers...

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