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BRUMLIK v. COMMISSIONER

Docket Nos. 21393-90, 21394-90.

75 T.C.M. 2401 (1998)

T.C. Memo. 1998-201

Timothy S. Brumlik v. Commissioner. Timothy S. Brumlik and Patricia A. Brumlik v. Commissioner.

United States Tax Court.

Filed June 2, 1998.

Attorney(s) appearing for the Case

Burton L. Bruggeman, for the petitioners. Benjamin A. de Luna, for the respondent.

MEMORANDUM OPINION

PARR, Judge:

These consolidated cases are before the Court on respondent's motions for summary judgment filed on December 18, 1997, pursuant to Rule 121.1 The issue for decision is whether the doctrine of res judicata applies so as to preclude petitioners from litigating the deficiencies determined by respondent in this Court. Respondent, in the notices of deficiency, dated June 28, 1990, determined deficiencies...

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