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RICHARDS v. COMMISSIONER

Docket No. 8922-87.

73 T.C.M. 2419 (1997)

T.C. Memo. 1997-149

Benness M. Richards and Jane Richards v. Commissioner.

United States Tax Court.

Filed March 24, 1997.

Attorney(s) appearing for the Case

Robert Alan Jones, for the petitioners.1 Pamela S. Wilson and Richard G. Goldman, for the respondent.

MEMORANDUM OPINION

BEGHE, Judge:

This matter is before the Court on petitioners' Motion for Leave to File Motion to Vacate Decision. The issue to be decided concerns the validity of the notice of deficiency and whether respondent "determined" a deficiency in petitioners' Federal income tax liability within the meaning of section 6212(a).2

Background

On or about June 25, 1979, Benness M. Richards and Jane...

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