T.C. Memo. 1999-78
UNITED STATES TAX COURT
PAUL K. HANASHIRO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10486-98. Filed March 12, 1999.
Bruce E. Gardner, for petitioner.
Melinda Williams, Peter Reilly, and John Q. Walsh, for
respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This case is before
the Court on petitioner's motion to dismiss for lack of
jurisdiction.1 Petitioner contends that the notices of
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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