-4-
Hickey a final notice of determination denying her any such
relief.
Following a short trial on these cases, inclusive of an
evidentiary hearing on a motion by petitioners to suppress all
documents and testimony (collectively, proffered evidence)
related to the Commissioner’s determinations and allegations of
fraud, we decide whether we shall grant that motion to suppress.2
We hold that we shall not. Given this holding, petitioners
concede all other issues in these cases, including their
liability for the deficiencies, additions to tax, penalties, and
accuracy-related penalties determined by respondent (except to
the extent conceded by respondent in his answers), and whether
Hickey is entitled to her requested relief under section 6015.
FINDINGS OF FACT
Some facts were stipulated. We incorporate herein by this
reference the parties’ stipulation of facts and the exhibits
submitted therewith. We find the stipulated facts accordingly.
2 Petitioners’ motion was filed as a motion to dismiss for
cause, or, alternatively, to suppress the proffered evidence. A
dismissal of the deficiency cases generally would require that
the Court enter decisions finding that the deficiencies in tax,
additions thereto, and penalties are the amounts determined in
the notices of deficiency. See Estate of Ming v. Commissioner,
62 T.C. 519 (1974); see also sec. 7459(d); cf. Wagner v.
Commissioner, 118 T.C. 330, 331-332 (2002). Given that result,
which petitioners obviously do not desire, we consider in the
deficiency cases only so much of their motion as relates to
suppression of evidence. We consider their motion in its
entirety in the remaining case.
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