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SALL v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 26815-22.

161 T.C. No. 13

MADIODIO SALL, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 30, 2023.

Attorney(s) appearing for the Case

Madiodio Sall, pro se.

Andrew J. Davis, for respondent.

OPINION

This case presents the Court's first opportunity to apply section 7451(b).1

Background

The Commissioner issued a notice of deficiency to Madiodio Sall and Ramatoulaye Fall for 2017 and 2018. The notice of deficiency was dated August 25, 2022. Although the notice...

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