T.C. Memo. 2002-94 UNITED STATES TAX COURT ROBERT HURFORD AND CATHERINE SIMONE HALE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13278-01L. Filed April 8, 2002. Robert Hurford and Catherine Simone Hale, pro sese. Robin Ferguson, for respondent. MEMORANDUM OPINION PANUTHOS, Chief Special Trial Judge: This matter is before the Court on: (1) Respondent’s oral motion to dismiss for lack of jurisdiction and to strike all allegations in the second amended petition pertaining to a Notice of Federal Tax Lien filed October 8, 1998, pertaining to a frivolous return penalty imposed against petitioners pursuant to section 6702; and (2) respondent’sPage: 1 2 3 4 5 6 7 8 9 10 11 Next
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