James E. Anderson and Cheryl J. Latos - Page 1

                                 T.C. Memo. 2000-311                                  

                               UNITED STATES TAX COURT                                

                JAMES E. ANDERSON AND CHERYL J. LATOS, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17158-99L.               Filed October 2, 2000.             

               James E. Anderson and Cheryl J. Latos, pro sese.                       
               John Aletta, for respondent.                                           

                                 MEMORANDUM OPINION                                   
               DEAN, Special Trial Judge:  This matter is before the Court            
          on respondent's motion to dismiss for lack of jurisdiction and to           
          strike as to the 1994 taxable year.  As discussed below, we shall           
          grant respondent's motion.                                                  
               James E. Anderson (petitioner) is employed as a commercial             
          fisherman.  The Commissioner determined that petitioner owed                

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