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TOSO v. COMMISSIONER

Docket No. 8324-15.

151 T.C. 27 (2018)

ROBERTO TOSO AND MARCELA SALMAN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 4, 2018.

Attorney(s) appearing for the Case

Robert S. Schwartz and Elizabeth C. Petite , for petitioners.

Steven D. Tillem , for respondent.

OPINION

By notice of deficiency, respondent determined deficiencies in petitioners' Federal income tax and penalties under section 6662 with respect to their tax years 2006, 2007, and 2008.1 After concessions,2 the issues

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