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GUSTAFSON v. COMMISSIONER

Docket No. 300-91.

97 T.C. 85 (1991)

RUSSELL F. AND BARBARA B. GUSTAFSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 29, 1991.

Attorney(s) appearing for the Case

Thomas F. Joyce, for the petitioners.

James P. Thurston, for the respondent.

OPINION

COHEN, Judge:

This case is before us on respondent's motion to dismiss for lack of jurisdiction on the ground that petitioners' claim for administrative costs is barred by the doctrine of res judicata. Petitioners were residents of Hillsborough, California, when their petition was filed.

Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule...

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