T.C. Memo. 2000-266 UNITED STATES TAX COURT LESTER L. AND SUSAN P. SAMFORD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13597-91. Filed August 24, 2000. Thomas E. Redding, for petitioners. Robert E. Marum, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION POWELL, Special Trial Judge: This case is before the Court on petitioners’ motion to dismiss for lack of jurisdiction. Petitioners are part of a group of investors in a partnership, Summer Lovers Associates (SLA). Six other partners, who have petitions pending in this Court, have also filed motions to dismiss. In those six cases the petitioners have agreed that this case will serve as the test case as to the motions to dismiss. This case was submitted fully stipulated under RulePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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