W. Brian McDermott - Page 1

                                 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.                                  

Page:  1  2  3  4  Next 

Last modified: November 10, 2007