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FRANCEL v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 6560-17L.

T.C. Memo. 2019-35

THOMAS J. FRANCEL, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 10, 2019.

Attorney(s) appearing for the Case

Charles A. James and Michael H. James , for petitioner.

Jessica R. Nolan and Philip Edward Blondin , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

The petitioner, Dr. Thomas J. Francel, filed joint returns with his wife for tax years 2003, 2004, 2005, and 2006. His wife pleaded guilty to evading tax for those years and made restitution to the United States. The restitution payment was credited by the Internal Revenue Service...

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