Michael Rising Sun - Page 7




                                        - 7 -                                         
               Petitioner is not without a judicial remedy.  Petitioner may           
          pay the tax and file a claim for refund with the Internal Revenue           
          Service.  If the claim for refund is denied, then petitioner may            
          pursue his case in the appropriate Federal District Court or the            
          U.S. Court of Federal Claims.  McCormick v. Commissioner, 55 T.C.           
          138, 142 (1970).                                                            
               To reflect the foregoing,                                              
                                        An order granting respondent's                
                                   motion to dismiss for lack of                      
                                   jurisdiction will be entered.                      































Page:  Previous  1  2  3  4  5  6  7  

Last modified: May 25, 2011