T.C. Memo. 2007-176 UNITED STATES TAX COURT JAMES GROVER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23598-06L. Filed July 3, 2007. James Grover, pro se. John R. Mikalchus, for respondent. MEMORANDUM OPINION THORNTON, Judge: This case is before us on respondent’s motion to dismiss for lack of jurisdiction. As discussed below, we must grant respondent’s motion.