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BECKER HOLDING CORPORATION v. COMMISSIONER

Docket No. 6400-03.

87 T.C.M. 1069 (2004)

T.C. Memo. 2004-58

Becker Holding Corporation and Subsidiaries v. Commissioner.

United States Tax Court.

Filed March 10, 2004.

Attorney(s) appearing for the Case

Jerald David August and James P. Dawson, for the petitioner.

Andrew M. Tiktin and Sergio Garcia-Pages, for the respondent.

MEMORANDUM OPINION

HAINES, Judge:

The matter is before the Court on the parties' cross-motions for partial summary judgment pursuant to Rule 121.1 The issues to be decided are: (1) Whether the parties agreed to a settlement with respect to petitioner's tax years ending September 30, 1994, 1995, and 1996 (years at issue); and, if not, (2) whether the notice of deficiency2 is barred because it was mailed...

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