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FOWLER v. COMMISSIONER

Docket No. 12810-18.

155 T.C. 106 (2020)

155 T.C. No. 7

ROBIN J. FOWLER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 9, 2020.

Attorney(s) appearing for the Case

David D. Aughtry and Patrick J. McCann, Jr. , for petitioner.

Joel D. McMahan and A. Gary Begun , for respondent.

OPINION

This case is before the Court on respondent's motion for partial summary judgment and petitioner's cross-motion for summary judgment under Rule 121.1 The issue for decision is whether as a matter of law the limitations period for petitioner's 2013 Federal income tax return expired before...

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