Michael Alan Jablonski - Page 1

                                         T.C. Memo. 1998-396                                              

                                      UNITED STATES TAX COURT                                             

                             MICHAEL ALAN JABLONSKI, Petitioner v.                                        
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                     

                  Docket No. 24874-97R.             Filed November 10, 1998.                              

                  Michael Alan Jablonski, pro se.                                                         
                  David W. Sorensen, for respondent.                                                      

                                         MEMORANDUM OPINION                                               
                  POWELL, Special Trial Judge:  This case is before the Court                             
            on respondent's motion to dismiss for lack of jurisdiction.                                   
            Petitioner filed a petition for declaratory judgment to review a                              
            favorable determination by respondent with respect to amendments                              
            to a retirement plan.                                                                         
                  The facts may be summarized as follows.  Petitioner was                                 
            employed by Design Analysis Associates, Inc. from September 1,                                
            1982, until November 1, 1989.  During part of his employment                                  

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