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CALLAHAN v. COMMISSIONER

No. 5701-07L.

130 T.C. 44 (2008)

DUDLEY JOSEPH CALLAHAN AND MYRNA DUPUY CALLAHAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 5, 2008.

Attorney(s) appearing for the Case

Dudley Joseph Callahan and Myrna Dupuy Callahan, pro sese.

Scott T. Welch, for respondent.

OPINION

HAINES, Judge:

This case is before the Court on respondent's motion for summary judgment filed pursuant to Rule 121.1 The issues for decision are:

(1) Whether we have jurisdiction to review respondent's determination issued under section 6330 when the underlying tax liability consists of frivolous return penalties. We hold that we do;

(2) whether in reviewing...

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