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the U.S. Code
1997 U.S. Code
Title 26 - INTERNAL REVENUE CODE
RULES OF PRACTICE AND PROCEDURE OF THE UNITED STATES TAXCOURT
TITLE IV - PLEADINGS
Rule 39 - Pleading Special Matters
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Rule 39. Pleading Special Matters
Rule 39. Pleading Special Matters
A party shall set forth in the party's pleading any matter constituting an avoidance or affirmative defense, including res judicata, collateral estoppel, estoppel, waiver, duress, fraud, and the statute of limitations. A mere denial in a responsive pleading will not be sufficient to raise any such issue.
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