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We will not decide whether Jeanie Henderson should be joined
as an appropriate party for 1997 when we lack subject matter
jurisdiction over the underlying tax liability. See Johnson v.
Commissioner, supra at 209 (declining to decide whether the
hearing requirement under section 6330(b) had been met when the
Court lacked subject matter jurisdiction (citing Yuen v.
Commissioner, 112 T.C. 123, 130 (1999) (declining to decide
whether a final notice of determination under section 6404 was
issued when the Court lacked subject matter jurisdiction))).
To reflect the foregoing,
An appropriate order will be
entered.
[REPORTER’S NOTE: THIS OPINION WAS AMENDED BY ORDER DATED AUGUST
10, 2004.]
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