Troy Enterprises Trust - Page 1

                                 T.C. Memo. 2000-227                                  

                               UNITED STATES TAX COURT                                

                  TROY ENTERPRISES TRUST, JOHN P. WILDE, TRUSTEE &                    
                   YALE ENTERPRISES TRUST, JOHN P. WILDE, TRUSTEE,                    
                           Petitioners v. COMMISSIONER OF                             
                            INTERNAL REVENUE, Respondent                              

               Docket No. 17893-99.                    Filed July 28, 2000.           

               John P. Wilde, for petitioners.                                        
               John W. Duncan, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               VASQUEZ, Judge:  This case is before the Court on                      
          respondent’s motion to dismiss for lack of jurisdiction.                    
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              

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