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In a court-reviewed opinion published on January 29, 2018, the U.S. Tax Court in Coffey, et. al. v. Commissioner, 150 T.C. No. 4, found in favor of the taxpayers and dismissed the Internal Revenue Service’s Statutory Notices of Deficiency against them as time barred. Andreozzi Bluestein LLP represented the Petitioners in this case before the Tax Court. The Petitioners claimed