T.C. Memo. 2003-181
UNITED STATES TAX COURT
MICHAEL T. HAWKINS AND JANINE M. HANSEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10747-01. Filed June 20, 2003.
Michael T. Hawkins and Janine M. Hansen, pro sese.
Alan J. Tomsic, for respondent.
MEMORANDUM OPINION
WOLFE, Special Trial Judge: This matter is before the Court
on petitioners’ Motion to Dismiss for Lack of Jurisdiction,
respondent’s Motion for Summary Judgment, and respondent’s Motion
to Impose a Penalty under Section 6673. Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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