KELBY v. COMMISSIONER

No. 13268-03L.

130 T.C. 79 (2008)

RICHARD AND MABEL KELBY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 28, 2008.


Attorney(s) appearing for the Case

William E. Taggart, Jr., for petitioners.

Rebecca Duewer-Grenville, for respondent.


OPINION

HAINES, Judge:

This collection review case under section 6330 is before the Court on the parties' cross-motions for entry of decision.1

Background

The parties have substantially agreed on the elements of a decision to be entered. However, they dispute certain aspects of the decision.

The cause of this dispute begins with petitioners' 1989 return. Petitioners contend that they timely...

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