Memorandum Opinion
PETERSON, Chief Special Trial Judge:
Respondent issued a notice of deficiency on April 4, 1988, for the taxable year 1983. A petition was filed on June 13, 1988. In the petition it was alleged that the notice of deficiency was issued in error since petitioners had settled their tax dispute with respondent at the audit level and paid the tax, additions to tax, and interest. Petitioner also alleged in his petition...
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