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KRAMER v. COMMISSIONER

Docket No. 3218-80

44 T.C.M. 42 (1982)

T.C. Memo. 1982-308

Harvey Kramer and Minna Kramer v. Commissioner.

United States Tax Court.

Filed June 7, 1982.

Attorney(s) appearing for the Case

Barry I. Fredericks, 655 Madison Ave., New York, N.Y., for the petitioners. Richard J. Sapinski, for the respondent.

Memorandum Opinion

SHIELDS, Judge:

This case is before the Court on petitioners' motion for partial summary judgment1 under Rule 121.2 The question to be decided is whether respondent's deficiency notice was timely mailed within the period provided by section 6501(a)3 with respect to the year 1969.

Respondent determined that deficiencies in income taxes and additions...

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