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TUCKER v. COMMISSIONER

Docket No. 7422-80.

45 T.C.M. 1347 (1983)

T.C. Memo. 1983-210

James P. Tucker, Jr. and Susana I. Tucker v. Commissioner.

United States Tax Court.

Filed April 18, 1983.

Attorney(s) appearing for the Case

James P. Tucker, Jr., pro se, Locust Grove, Va. Lawrence D. Garr, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1976 in the amount of $3,618. After concessions by the parties, the issue for decision is whether assessment of a deficiency is barred by either (a) the provisions relating to repetitive examinations in respondent's Internal Revenue Manual or (b) the doctrine...

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