T.C. Memo. 2002-15
UNITED STATES TAX COURT
FRANKLIN A. OGDEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3343-01L. Filed January 15, 2002.
Franklin A. Ogden, pro se.
Gerald W. Douglas, Karen Baker and Peter Reilly, for
respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This collection review
case is before the Court on respondent’s motion to dismiss for
lack of jurisdiction. As explained in detail below, we shall
grant respondent’s motion to dismiss.1
1 Unless otherwise indicated, section references are to
sections of the Internal Revenue Code, as amended, and Rule
(continued...)
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