T.C. Memo. 1996-384
UNITED STATES TAX COURT
ROBERT C. OLSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22213-94. Filed August 20, 1996.
Larry D. Harvey, for petitioner.
David P. Monson, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent's Motion to Dismiss for Lack of Jurisdiction and to
Strike Partnership Items (respondent's Motion to Dismiss). The
issue raised by respondent's Motion to Dismiss involves the scope
of this Court's jurisdiction in a so-called affected items
proceeding involving additions to tax for negligence and
substantial understatement of income tax.
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