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CHARLOTTE'S OFFICE BOUTIQUE, INC. v. COMMISSIONER

Docket No. 5077-01.

87 T.C.M. 998 (2004)

T.C. Memo. 2004-43

Charlotte's Office Boutique, Inc. v. Commissioner.

United States Tax Court.

Filed February 25, 2004.

Attorney(s) appearing for the Case

Robert E. Kovacevich, for the petitioner.

Milton B. Blouke, for the respondent.

SUPPLEMENTAL MEMORANDUM OPINION

LARO, Judge.

In Charlotte's Office Boutique, Inc. v. Commissioner [Dec. 55,254], 121 T.C. 89 (2003), an employment tax case brought under section 7436(a),1 we held that petitioner is liable for unreported 1995 through 1998 employment taxes and certain additions thereto under sections 6651(a)(1) and 6656. Petitioner now asserts that the Court lacked jurisdiction to redetermine the referenced...

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