Hanna & Associates, P.C. - Page 1


                                 T.C. Memo. 1998-210                                  

          UNITED STATES TAX COURT                                                     

                             HANNA & ASSOCIATES, P.C.,                                
          FORMERLY MARK J. HANNA, P.C., Petitioner v.                                 
          COMMISSIONER OF INTERNAL REVENUE, Respondent                                

               Docket No. 10734-97.              Filed June 16, 1998.                 

               Charles F. Daily, Jr., for petitioner.                                 
               Steven B. Bass, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               PARR, Judge:   This case is before the Court on respondent's           
          motion to dismiss for lack of jurisdiction filed on June 30,                
          1997,1 pursuant to Rule 53.2  The issue for decision is whether             

          1    On August 25, 1997, respondent filed an amendment to                   

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