T.C. Memo. 2001-29
UNITED STATES TAX COURT
JOHN D. SPIVEY AND PAMELA K. SPIVEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19180-99. Filed February 8, 2001.
David D. Aughtry and Brett W. Beveridge, for petitioners.
Gwendolyn C. Walker, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: This case is before us on cross-motions to
dismiss for lack of jurisdiction (cross-motions). On September
11, 2000, the Court held a hearing (hearing) on the parties’
cross-motions.
Petitioners moved to dismiss this case for lack of jurisdic-
tion on the following alternative grounds: (1) No notice of
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