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BATTAT v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 17784-12.

T.C. Memo. 2021-57

STANLEY BATTAT AND ZMIRA BATTAT, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 11, 2021.

Attorney(s) appearing for the Case

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

W. Robert Abramitis and Daniel C. Munce , for respondent.

MEMORANDUM OPINION

This case is before the Court on petitioners' motion for partial summary judgment. The issue for decision is whether the Form 4549, Income Tax Examination Changes, also known as a revenue agent report (RAR),1 sent with a Letter 4121, Agreed Examination Report Transmittal, was...

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