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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