Robert Scott Dunning, Petitioner-appellant, v. Commissioner of Internal Revenue, Respondent-appellee, 861 F.2d 263 (4th Cir. 1988)

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US Court of Appeals for the Fourth Circuit - 861 F.2d 263 (4th Cir. 1988) Submitted: May 25, 1988. Decided: Oct. 20, 1988

Before DONALD RUSSELL, SPROUSE and CHAPMAN, Circuit Judges.

Robert Scott Dunning, appellant pro se.

Gary R. Allen, William S. Rose, Jr. (United States Department of Justice), for appellee.

PER CURIAM:


A review of the record, the opinion of the Tax Court, and the informal briefs submitted by the parties to this appeal reveals that the Tax Court's determination that Dunning failed to rebut the presumption of correctness that attaches to an IRS deficiency notice was proper. We accordingly affirm the decision of the Tax Court based on its reasoning. Dunning v. Commissioner of Internal Revenue, TC No. 18206-87 (Dec. 23, 1987).

Because the facts and legal contentions are adequately developed in the materials before the Court and oral argument would not aid in the decisional process, we dispense with argument in his case.

AFFIRMED.

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