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 declaratory
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