T.C. Memo. 2001-300
UNITED STATES TAX COURT
ROBERT BAXTER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7177-00L. Filed November 13, 2001.
Robert Baxter, pro se.
John Y. Chinnapongse, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: This case was called from the
calendar of the trial session at San Francisco, California, on
January 22, 2001, for hearing on respondent’s Motion to Dismiss
for Failure to State a Claim Upon Which Relief Can Be Granted,
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