T.C. Memo. 1996-544
UNITED STATES TAX COURT
JILL R. SCOTT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3072-96. Filed December 17, 1996.
Jill R. Scott, pro se.
Jordan S. Musen and Benjamin A. de Luna, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's motion to dismiss for lack of
jurisdiction and petitioner's motion to restrain assessment and
collection. As explained in greater detail below, we shall grant
respondent's motion and deny petitioner's motion.
Background
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