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LINCIR v. COMMISSIONER

Dkt. No. 10138-04.

93 T.C.M. 1098 (2007)

T.C. Memo. 2007-86

Diane C. Lincir v. Commissioner.

United States Tax Court.

April 11, 2007.

Attorney(s) appearing for the Case

Michael D. Savage, for petitioner.

Michael R. Skutley, for respondent.

MEMORANDUM OPINION

CHABOT, Judge:

This matter is before us on petitioner's motion under Rule 1211 for partial summary judgment that petitioner is permitted to claim relief under section 60152 for 1978 through 1982, because relief under that section was not available to her when she litigated income tax deficiencies for the same years in a prior case in...

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