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PROSSER v. C.I.R.

Nos. 13-4526-ag (L), 13-4527-ag (CON).

777 F.3d 582 (2015)

Robert L. PROSSER, III, Mary C. Prosser, McGehee Family Clinic, P.A., Petitioners-Appellants, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided: February 4, 2015.

Attorney(s) appearing for the Case

John T. Morin ( Ira B. Stechel , on the brief), Wormser, Kiely, Galef & Jacobs LLP, New York, NY, for Petitioners-Appellants.

Randolph L. Hutter ( Tamara W. Ashford , Acting Assistant Attorney General; Thomas J. Clark , on the brief), Tax Division, Department of Justice, Washington, D.C., for Respondent-Appellee.

Before: JACOBS, SACK, and DRONEY, Circuit Judges.

Robert and Mary Prosser ("the Prossers") and the McGehee Family Clinic ("the Clinic," and collectively "Petitioners") filed petitions for redetermination in the United States Tax Court challenging the Commissioner of Internal Revenue's ("Commissioner") determination of tax deficiencies and assessment of penalties against them...

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