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MALONE v. COMMISSIONER

Docket No. 22750-09.

148 T.C. 372 (2017)

148 T.C. No. 16

BERNARD P. MALONE AND MARY ELLEN MALONE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 1, 2017.

Attorney(s) appearing for the Case

Val J. Albright and Brent C. Gardner, for petitioners.

Christopher M. Menczer, Heather L. Lampert, and Linda L. Wong, for respondent.

OPINION

This matter is before the Court on the Malones' motion to dismiss for lack of jurisdiction the portion of this case that relates to the section 6662(a) penalty that the Commissioner asserted because the Malones did not report certain partnership items on their joint 2005 Form 1040, U.S. Individual Income Tax Return...

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