T.C. Memo. 1996-377
UNITED STATES TAX COURT
PETER PETTONG AND CHUNG-YIN CHIANG, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3642-94. Filed August 15, 1996.
Peter Pettong Chiang, pro se.
Stephanie Jensen, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 183.1 This matter is before the Court on respondent's
motion to dismiss for lack of jurisdiction. Respondent moved for
dismissal on the grounds that the notice of deficiency for
1 All section references are to the Internal Revenue Code as
amended, unless otherwise indicated. All Rule references are to
the Tax Court Rules of Practice and Procedure.
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