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 Rule
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