Kenneth A. Sapp - Page 1

                                 T.C. Memo. 2003-207                                   

                               UNITED STATES TAX COURT                                 

                            KENNETH A. SAPP, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 5759-02L.             Filed July 15, 2003.                   

               Kenneth A. Sapp, pro se.                                                
               Veena Luthra, for respondent.                                           

                                  MEMORANDUM OPINION                                   

               CHIECHI, Judge:  This case is before us on petitioner’s                 
          motion to dismiss for lack of jurisdiction.1  We shall deny that             

               1Petitioner filed a memorandum (petitioner’s memorandum) in             
          support of his motion to dismiss for lack of jurisdiction.  (We              
          shall refer collectively to that motion and that memorandum as               
          petitioner’s motion.)                                                        

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