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GEHRAU v. COMMISSIONER

Docket No. 12561-92.

67 T.C.M. 2336 (1994)

T.C. Memo. 1994-94

Eugen Gehrau and Roselyne Gehrau v. Commissioner.

United States Tax Court.

Filed March 3, 1994.

Attorney(s) appearing for the Case

Daniel J. Parent, for the respondent.

Memorandum Opinion

CHIECHI, Judge:

This case is before the Court on respondent's motion under Rules 123(a)1 and 104(c)(3) requesting an entry of default against petitioners and dismissal of their case on the merits. Respondent further moved that the Court require petitioners to pay a penalty to the United States pursuant to section 6673.

Background

Respondent determined the following deficiencies in,...

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