T.C. Memo. 2002-139
UNITED STATES TAX COURT
ROBERT L. STEWART, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12947-00. Filed May 31, 2002.
Robert L. Stewart, pro se.
Catherine L. Campbell, for respondent.
MEMORANDUM OPINION
RUWE, Judge: This matter is before the Court on
respondent’s Motion to Dismiss for Lack of Jurisdiction and to
Strike Claim for Abatement of Additions to Tax. Respondent’s
motion is based on the ground that petitioner, in addition to
seeking abatement of interest, is seeking abatement of an
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