William M. Hezel - Page 6

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          As a final matter, we turn to petitioner's motions to                       
          restrain assessment and collection.  Section 6213(a) provides               
          that the Tax Court may enjoin assessment or collection if the               
          Commissioner is attempting to assess or collect amounts that have           
          been placed in dispute in a timely-filed petition for                       
          redetermination.  Powerstein v. Commissioner, 99 T.C. 466, 471-             
          472 (1992); Powell v. Commissioner, 96 T.C. 707, 711 (1991).  The           
          record reflects that the amounts that respondent has assessed and           
          is attempting to collect relate to petitioner's tax liability for           
          1989, 1990, 1991, 1992.  As a consequence of our holding that we            
          lack jurisdiction over those years, it follows that we lack                 
          jurisdiction to enjoin assessment and collection.  Powell v.                
          Commissioner, supra.  Accordingly, we will deny petitioner's                
          motions for lack of jurisdiction.                                           
          To reflect the foregoing,                                                   

                                            Appropirate orders granting              
                              respondent's motions, denying petitioner's              
                              motions, and dismissing these cases for                 
                              lack of jurisdiction will be entered.                   

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