T.C. Memo. 1999-275 UNITED STATES TAX COURT FRANK A. SONIER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13527-98R. Filed August 17, 1999. Frank A. Sonier, pro se. Lawrence H. Ackerman, for respondent. MEMORANDUM OPINION DEAN, Special Trial Judge: This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. The issues for decision are: (1) Whether petitioner has alleged that there is an actual controversy; and (2) whether petitioner is an "interested party" entitled to file a petition for declaratoryPage: 1 2 3 4 5 6 7 8 9 Next
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