T.C. Memo. 2005-222
UNITED STATES TAX COURT
THOMAS J. & GISELLA SABATH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 378-04L. Filed September 26, 2005.
Gregory A. Stout, for petitioners.
Stephen J. Neubeck, for respondent.
MEMORANDUM OPINION
LARO, Judge: Petitioners petitioned the Court under section
6330(d) to review a determination made by the Commissioner‘s
Office of Appeals (Appeals) as to their 1986 and 1990 through
1997 Federal income tax liability.1 While petitioners alleged in
1 Unless otherwise indicated, section references are to the
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