T.C. Memo. 2000-223
UNITED STATES TAX COURT
JOHN J. FLYNN AND JAMES H. THOMAS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18090-99R. Filed July 28, 2000.
Michael Samuel Gordon, for petitioners.
Sandra M. Jefferson, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's motion to dismiss for lack of
jurisdiction. The issue for decision is whether petitioners are
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