Manley Mullings and Melvina Barnes-Mullings - Page 9

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          dismiss, that no deficiency notice had been issued for 1986.  See           
          Pietanza v. Commissioner, T.C. Memo. 1990-524.  On this record,             
          we hold respondent to her initial representations and adhere to             
          our initial order dismissing this case as to 1986 on the ground             
          that respondent failed to issue a deficiency notice.                        



               Accordingly,                                                           
                                   An order will be issued denying                    
                              petitioners' motion to vacate order of                  
                              dismissal.                                              



























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