T.C. Memo. 1997-560
UNITED STATES TAX COURT
WILLIAM L. AND MARY LEE POWELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10560-96. Filed December 22, 1997.
Valentine C. Crotin, for petitioners.
Alvin A. Ohm and Andrew M. Winkler, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182.1 This matter
is before the Court on respondent's Motion to Dismiss for Lack of
Jurisdiction. The issue raised by respondent's motion to dismiss
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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