T.C. Memo. 1998-142
UNITED STATES TAX COURT
RICHARD L. PICKERING, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19487-97. Filed April 16, 1998.
Richard L. Pickering, pro se.
Richard Fultz, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This case was assigned pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1
This case is before the Court on respondent's Motion to
Dismiss for Lack of Jurisdiction, filed November 25, 1997. There
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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