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ALLEN v. COMMISSIONER

Docket No. 11016-05.

128 T.C. 37 (2007)

128 T.C. No. 4

VINCENT ALLEN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 5, 2007.

Attorney(s) appearing for the Case

Forest J. Dorkowski, for petitioner.

Caroline R. Krivacka, for respondent.

OPINION

KROUPA, Judge:

Respondent determined a $4,428 deficiency in petitioner's Federal income tax for 1999 and a $7,784 deficiency in petitioner's Federal income tax for 2000. We are asked to decide for the first time whether the limitations period for assessing income tax under section 6501(c)(1)1 is extended if the tax on a return is understated due to the fraudulent intent of the income tax return preparer. We conclude...

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