T.C. Memo. 1997-489
UNITED STATES TAX COURT
HAROLD L. PERRY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15108-97. Filed October 29, 1997.
Jordan Musen, for respondent.
MEMORANDUM OPINION
CARLUZZO, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) of the
Internal Revenue Code, and Rules 180, 181, and 182,1 and is
before the Court on respondent's Motion to Dismiss for Failure
1Rule references are to the Tax Court Rules of Practice and
Procedure.
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