T.C. Memo. 2006-18
UNITED STATES TAX COURT
KIMBERLEY A. PARLIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4904-05. Filed February 6, 2006.
Stephen K. Midgley, for petitioner.
Louise R. Forbes, for respondent.
MEMORANDUM OPINION
THORNTON, Judge: This case is before us on respondent’s
motion to dismiss for lack of jurisdiction. For the reasons
stated below, we must grant respondent’s motion.
Background
On February 11, 2004, petitioner executed Form 2848, Power
of Attorney and Declaration of Representative, appointing
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