T.C. Memo. 2007-374
UNITED STATES TAX COURT
MARC AND SHERRI WARD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14688-06. Filed December 26, 2007.
Eugene A. Steger, Jr., for petitioners.
Harry J. Negro, for respondent.
MEMORANDUM OPINION
GALE, Judge: This matter is before the Court on
respondent's motion to dismiss for lack of jurisdiction.1 In his
motion, respondent contends that no notice was issued to
petitioners upon which to form the basis for a petition to this
1 In addition, petitioners submitted a document to the Court
that was filed as a motion to restrain assessment or collection.
See discussion infra note 6.
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