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THOMPSON v. COMMISSIONER

Docket No. 6613-13.

155 T.C. 87 (2020)

155 T.C. No. 5

DOUGLAS M. THOMPSON AND LISA MAE THOMPSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 31, 2020.

Attorney(s) appearing for the Case

Joseph A. DiRuzzo III and Daniel M. Lader, for petitioners.

Thomas A. Deamus and Robert C. Marshall, for respondent.

OPINION

This case is before the Court on petitioners' motion for partial summary judgment under Rule 121 (motion).1 A revenue agent sent letters to petitioners offering to settle their tax liabilities as to an abusive transaction. Terms of the settlement offers required petitioners to agree...

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