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CORBALIS v. COMMISSIONER

Docket No. 8220-13.

142 T.C. 46 (2014)

CHARLES M. CORBALIS AND LINDA J. CORBALIS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 27, 2014.

Attorney(s) appearing for the Case

Cory Stigile, Sharyn M. Fisk, Della J. Bauserman, and Charles Paul Rettig, for petitioners.

Najah J. Shariff, for respondent.

OPINION

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. The primary issue for decision is whether section 6404(h) applies to denials of interest suspension under section 6404(g). If so, we must decide whether the notice from which petitioners...

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