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U.S. AUTO SALES, INC. v. COMMISSIONER

Docket No. 20050-12.

153 T.C. 94 (2019)

U.S. AUTO SALES, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 28, 2019.

Attorney(s) appearing for the Case

Joseph C. Mandarino, Anthony J. Rollins, and John Phillip Tyler, for petitioner.

Anita Goklaney, Carolyn L. Rountree, and Gwendolyn C. Walker, for respondent.

OPINION

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. The issue presented by respondent's motion is whether the notice of deficiency underlying this case is invalid because it does not reflect that respondent made a deficiency determination as to petitioner within the meaning of...

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