T.C. Memo. 1997-95
UNITED STATES TAX COURT
LIFE CARE COMMUNITIES OF AMERICA, LTD., A FLORIDA
LIMITED PARTNERSHIP, ROBERT W. AND JOHANNA McMICHAEL,
PARTNERS OTHER THAN THE TAX MATTERS PARTNER, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21683-94. Filed February 24, 1997.
Stanley W. Rosenkranz, Leonard L. Kleinman, and Glenn M.
Burton, for petitioners.
Francis C. Mucciolo and Benjamin A. deLuna, for respondent.
MEMORANDUM OPINION
PANUTHOS: Chief Special Trial Judge: This matter is before
the Court on two unrelated motions: (1) Respondent's motion to
dismiss for lack of jurisdiction and to strike allegations set
forth in the petition that Johanna McMichael is entitled to
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