Justice James and Lisa Onah - Page 1

                                 T.C. Memo. 1997-514                                  

                               UNITED STATES TAX COURT                                

                     JUSTICE JAMES AND LISA ONAH, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 1546-97.                 Filed November 14, 1997.           
               Justice James Onah, pro se.                                            
               Mark A. Weiner, for respondent.                                        
                                 MEMORANDUM OPINION                                   

               NAMEROFF, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7443A(b)(3)1 and Rules 180, 181, and           
          183.  This case is before the Court on respondent’s motion to               
          dismiss for lack of jurisdiction and to strike as to taxable year           
          1993.  Respondent’s motion is based upon petitioners’ failure to            

          1  All section references are to the Internal Revenue Code.                 
          All Rule references are to the Tax Court Rules of Practice and              

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