Thomas J. Nehrlich - Page 1

                                 T.C. Memo. 2007-88                                   

                               UNITED STATES TAX COURT                                

                          THOMAS J. NEHRLICH, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 20720-04L.             Filed April 12, 2007.                

               Patrick J. Quinn, for petitioner.                                      
               Catherine G. Chang, for respondent.                                    

                                 MEMORANDUM OPINION                                   

               HOLMES, Judge:  After a partnership named JTA Research was             
          audited, one of its partners filed a petition in this Court                 
          challenging the disallowance of a large charitable deduction.               
          But he filed the petition too late and we dismissed it for lack             
          of jurisdiction.  The Commissioner then assessed each of JTA's              

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Last modified: November 10, 2007