United States Tax Court February 11, 2004, 26005-96, 2266-97 (Thomas E. Johnston and Thomas E. Johnston, Successor in Interest to Shirley L. Johnston v. Commissioner)

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United States · · · 11-02-2004

122 T.C. No. 6

UNITED STATES TAX COURT

THOMAS E. JOHNSTON and THOMAS E. JOHNSTON, SUCCESSOR IN INTEREST

TO SHIRLEY L. JOHNSTON, DECEASED, Petitioners v.

COMMISSIONER OF INTERNAL REVENUE, Respondent*

THOMAS E. JOHNSTON, Petitioner v. COMMISSIONER OF INTERNAL

REVENUE, Respondent

Docket Nos. 26005-96, 2266-97. Filed February 11, 2004

Ps made a qualified offer, pursuant to sec. 7430,

I.R.C.

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