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 (continued...)Page: 1 2 3 4 5 6 7 8 9 10 Next
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