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STAHL v. COMMISSIONER

Docket No. 29441-85.

96 T.C. 798 (1991)

HARRY J. STAHL AND THEODORA G. STAHL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 10, 1991.

Attorney(s) appearing for the Case

Larry Kars, for the petitioners.

Marilyn Devin, for the respondent.

SUPPLEMENTAL OPINION

SWIFT, Judge:

Petitioners move to vacate and revise our opinion herein filed on June 26, 1990. See Stahl v. Commissioner, T.C. Memo. 1990-320.

Petitioners' motion is based on the contention that respondent's notices of deficiency mailed to petitioners on May 2, 1985, were untimely because they reflect adjustments to the 1979 and 1980 income of a partnership and because respondent...

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