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SABATH v. COMMISSIONER

Docket No. 378-04L.

90 T.C.M. 315 (2005)

T.C. Memo. 2005-222

Thomas J. & Gisella Sabath v. Commissioner.

United States Tax Court.

September 26, 2005.

Attorney(s) appearing for the Case

Gregory A. Stout, for petitioners.

Stephen J. Neubeck, for respondent.

MEMORANDUM OPINION

LARO, Judge:

Petitioners petitioned the Court under section 6330(d) to review a determination made by the Commissioner's Office of Appeals (Appeals) as to their 1986 and 1990 through 1997 Federal income tax liability.1 While petitioners alleged in their petition that their underlying tax liability for those years was different from that shown as due in respondent's records, respondent alleged in his answer...

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