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SMITH v. COMMISSIONER

Docket No. 2859-92.

68 T.C.M. 361 (1994)

T.C. Memo. 1994-378

Jeremy Smith v. Commissioner.

United States Tax Court.

Filed August 15, 1994.

Attorney(s) appearing for the Case

Jay Fetman, 1629 Litle John Court, Highland Park, Ill., for the petitioner. William E. Bogner, for the respondent.

Memorandum Opinion

SWIFT, Judge:

This case is before the Court on respondent's motion under Rule 50 for entry of decision on a stipulated settlement. All section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.

On December 6, 1991, respondent mailed to petitioner a notice of deficiency regarding petitioner's Federal income tax returns...

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