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Summary Opinion 2016-71 UNITED STATES TAX COURT HECTOR BAWAK BESONG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 30447-13S. UNITED STATES TAX COURT FLEMING CARDIOVASCULAR, P.A., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10776-13R. Filed November 23, 2015. Mark Eldridge (an officer), for petitioner. Pamela J. Sewell, for respondent. MEMORANDUM OPINION HAINES, Judge: In this declaratory judgment proceeding under section
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