Kimberley A. Parlin - Page 1

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                                 T.C. Memo. 2006-18                                   


                               UNITED STATES TAX COURT                                


                         KIMBERLEY A. PARLIN, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4904-05.               Filed February 6, 2006.              


               Stephen K. Midgley, for petitioner.                                    
               Louise R. Forbes, for respondent.                                      


                                 MEMORANDUM OPINION                                   

               THORNTON, Judge:  This case is before us on respondent’s               
          motion to dismiss for lack of jurisdiction.  For the reasons                
          stated below, we must grant respondent’s motion.                            
                                     Background                                       
               On February 11, 2004, petitioner executed Form 2848, Power             
          of Attorney and Declaration of Representative, appointing