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KUYKENDALL v. COMMISSIONER

Docket No. 16232-06L.

129 T.C. 77 (2007)

129 T.C. No. 9

ALAN LEE AND DEBI MARIE KUYKENDALL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 25, 2007.

Attorney(s) appearing for the Case

Alan Lee and Debi Marie Kuykendall, pro sese.

Emily Giometti, for respondent.

OPINION

HAINES, Judge:

This case is before the Court on respondent's motion for summary judgment filed pursuant to Rule 121.1 Respondent's motion argues that petitioners were statutorily barred from challenging the existence or amount of the underlying tax liability in their section 6330 hearing because they had received a notice of deficiency, and therefore, they are barred from...

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