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BROWN v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 18104-17L.

T.C. Memo. 2021-112

MICHAEL D. BROWN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 23, 2021.

Attorney(s) appearing for the Case

Steven R. Mather, for petitioner.

Kevin W. Coy, Hans Famularo, Regina S. Moriarty, and Francesca M. Ugolini, for respondent.

SUPPLEMENTAL MEMORANDUM OPINION

The U.S. Court of Appeals for the Ninth Circuit remanded this case with instructions to consider whether this Court has jurisdiction to order the refund of a Tax Increase Prevention and Reconciliation Act (TIPRA) payment. See Brown v. Commissioner (Brown...

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