T.C. Memo. 2007-205
UNITED STATES TAX COURT
W. BRIAN McDERMOTT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19530-06. Filed July 26, 2007.
W. Brian McDermott, pro se.
Robert M. Fowler, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: This matter is before us on respondent’s
motion to dismiss for lack of jurisdiction.1 Respondent also
1 Petitioner herein also has filed a motion to dismiss
which is being held in abeyance until resolution of respondent’s
motion to dismiss. Petitioner’s motion to dismiss is based on an
allegedly invalid notice of deficiency under the Tax Equity and
Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, 96
Stat. 324, partnership rules of sec. 6221.
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Last modified: November 10, 2007