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TODAY'S HEALTH CARE II LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 25541-18.

T.C. Memo. 2021-96

TODAY'S HEALTH CARE II LLC, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 2, 2021.

Attorney(s) appearing for the Case

Paul J. Valentine and Jared W. Miller , for petitioner.

Rebecca E. da Costa , Alicia E. Elliott , and Rachel J. Zepeda , for respondent.

MEMORANDUM OPINION

Pursuant to section 6212(a),1 the Internal Revenue Service ("IRS") determined deficiencies in tax and penalties for petitioner, Today's Health Care II LLC ("THC"), and mailed THC a statutory notice of deficiency ("SNOD") on September 26, 2018. The SNOD determined deficiencies...

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