T.C. Memo. 2001-138
UNITED STATES TAX COURT
KENNETH J. SIGEL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1851-00. Filed June 12, 2001.
Kenneth J. Sigel, pro se.
Frederick Petrino, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: This case is before us on respondent's motion
to dismiss. The issue presented is whether we lack jurisdiction
over petitioner's claims that an addition to tax under section
6654(a) should be waived and that assessed interest should be
abated under section 6404.
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