T.C. Memo. 2006-132
UNITED STATES TAX COURT
THOMAS H. CASSEL III & JONITA M. CASSEL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5462-05. Filed June 26, 2006.
Thomas H. Cassel III and Jonita M. Cassel, pro sese.
Brooke W. Patterson, for respondent.
MEMORANDUM OPINION
LARO, Judge: Respondent moves the Court to dismiss this
case for lack of jurisdiction, asserting that the petition
commencing this case was filed with the Court in violation of the
automatic stay of 11 U.S.C. section 362(a)(8) (2000).
Petitioners object to respondent’s motion, arguing that
respondent has waived the right to challenge the Court’s
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