Marc and Sherri Ward - Page 1

                              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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