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HEFTI v. COMMISSIONER

Docket No. 4447-88.

97 T.C. 180 (1991)

CHARLES AND MARION HEFTI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 31, 1991.

Attorney(s) appearing for the Case

Charles M. Shaw, for the petitioners.

Anthony S. Gasaway and Donald L. Wells, for the respondent.

SUPPLEMENTAL OPINION

SHIELDS, Judge:

This case was remanded by the Court of Appeals for the Eighth Circuit for consideration by us of section 301.7609-5(b), Proced. & Admin. Regs., vis-á-vis the suspension under section 7609(e)1 of the period of limitations provided by section 6501(a).

On April 15, 1984, petitioners filed with the Internal Revenue Service (IRS...

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