T.C. Memo. 1996-88
UNITED STATES TAX COURT
JOHN W. AND VINCENTIA SCHWARTZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 19269-92, 7275-93. Filed February 29, 1996.
Gene M. Zafft and John W. Schwartz, Jr., for petitioners.
Robert J. Burbank and Thomas C. Pliske, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: These consolidated cases
were assigned for hearing pursuant to section 7443A(b)(4) and
Rules 180, 181, and 183.1
These cases are before the Court on petitioners' motions to
dismiss for lack of jurisdiction. In their motions, petitioners
1 Unless otherwise indicated, all section references are to the
Internal Revenue Code as amended. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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