T.C. Memo. 2000-273
UNITED STATES TAX COURT
MALVERN HILLS TRUST, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16054-99. Filed August 29, 2000.
Cheryl R. Frank and Gerald W. Kelly, for petitioner.1
Mary Ann Waters, for respondent.
MEMORANDUM OPINION
LARO, Judge: Respondent moves the Court to dismiss this
case for lack of jurisdiction, arguing that the petition was not
filed with the Court by a proper party as required by Rule
1 Ms. Frank and Mr. Kelly entered their appearance on July
17, 2000. Petitioner’s petition was filed with the Court by
petitioner’s contractor, David Jablonski (Mr. Jablonski).
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