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MALL v. COMMISSIONER

Docket No. 17216-79.

41 T.C.M. 1568 (1981)

T.C. Memo. 1981-253

David and Adelle Mall v. Commissioner.

United States Tax Court.

Filed May 26, 1981.

Attorney(s) appearing for the Case

Marvin J. Rosenblum, 33 North Dearborn St., Chicago, Ill. for the petitioners. Tom P. Quinn, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

This matter is presently before the Court on respondent's motion to dismiss for lack of jurisdiction. This motion requires us to determine whether respondent's rejection of petitioners' offer in compromise constituted a notice of deficiency within the meaning of sections 6212 and 6213(a)1 so as to invoke the jurisdiction of this Court upon the filing of a petition for redetermination...

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