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CAPLETTE v. COMMISSIONER

Docket No. 21774-92.

65 T.C.M. 1876 (1993)

T.C. Memo. 1993-46

Raymond Joseph Caplette v. Commissioner.

United States Tax Court.

Filed February 4, 1993.

Attorney(s) appearing for the Case

Raymond Joseph Caplette, pro se. William A. McCarthy, for the respondent.

Memorandum Opinion

NAMEROFF, Special Trial Judge:

This case was assigned pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183. This case is before the Court on respondent's motion to dismiss for failure to state a claim for relief pursuant to Rule 40 and for penalties under section 6673 filed on November 16, 1992.

In a notice of deficiency dated June 29, 1992, respondent determined deficiencies in income tax and...

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