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BARKETT v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 28223-12.

143 T.C. 149 (2014)

G. DOUGLAS BARKETT AND RITA M. BARKETT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 28, 2014.

Attorney(s) appearing for the Case

Ernest S. Ryder, Richard V. Vermazen, and Lauren A. Rinsky, for petitioners.

Mistala M. Cullen and Monica D. Polo, for respondent.

OPINION

This matter is before us on petitioners' motion for partial summary judgment under Rule 121(a).1

Respondent issued a notice of deficiency concerning petitioners' Federal income tax for the taxable years 2006 to 2009. Petitioners contend that the notice is invalid as it relates...

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