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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