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DESMET v. C.I.R.

Nos. 08-1598, 08-1676.

581 F.3d 297 (2009)

Daniel J. DESMET, Linda K. Desmet (08-1598); Michael V. Domulewicz, Mary Ann Domulewicz (08-1676), Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: September 17, 2009.

Attorney(s) appearing for the Case

ARGUED: David D. Aughtry, Chamberlain, Hrdlicka, White, Williams, & Martin, Atlanta, Georgia, for Appellants. Michael J. Haungs, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: David D. Aughtry, Chamberlain, Hrdlicka, White, Williams, & Martin, Atlanta, Georgia, for Appellants. Michael J. Haungs, Deborah K. Snyder, United States Department of Justice, Washington, D.C., for Appellee.

Before CLAY and GIBBONS, Circuit Judges; GREER, District Judge.

OPINION

JULIA SMITH GIBBONS, Circuit Judge.

In these consolidated appeals, petitioners-appellants Daniel J. Desmet, Linda K. Desmet, Michael V. Domulewicz, and Mary Ann Domulewicz appeal orders of the United States Tax Court assessing income tax deficiencies of $2,497,934 against the Desmets and $1,250,099 against the Domulewiczes for the 1999 tax year. The petitioners do not dispute the amounts owed, but they argue that the tax court lacked jurisdiction...

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