Jeffrey Paul Schmidt - Page 5

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          authority of the United States to tax his income.  At trial, we                    
          reserved our right to rule on that motion at a later time; we                      
          proceeded under the assumption that this Court has jurisdiction.                   
                                          OPINION                                            
          Issue 1.  Motion to Dismiss for Lack of Jurisdiction                               
                Petitioner asserts that this Court lacks jurisdiction to                     
          hear his case.  Respondent asserts that petitioner's arguments                     
          are standard tax protester rhetoric and have long since been                       
          rejected by this Court.                                                            
                It suffices to say that petitioner chose this forum in which                 
          to litigate his tax dispute.  The Court acquired jurisdiction in                   
          this case after a valid notice of deficiency was sent to                           
          petitioner, and he in turn filed a timely petition.  Secs.                         
          6212(a) and (b), 6213(a); Minovich v. Commissioner, T.C. Memo.                     
          1994-39.  Once the Court's jurisdiction is invoked, it remains                     
          unimpaired until we decide the controversy.  Dorl v.                               
          Commissioner, 57 T.C. 720, 722 (1972), affd. per curiam without                    
          opinion 507 F.2d 406 (2d Cir. 1974).  Accordingly, petitioner's                    
          motion to dismiss for lack of jurisdiction is denied.                              
          Issue 2.  Unreported Income                                                        
                Respondent determined deficiencies in petitioner's gross                     
          income for the years at issue.  Petitioner asserts that he is a                    
          nonresident alien "without" the taxing authority of the United                     
          States.  Respondent asserts that petitioner is liable for tax on                   






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