T.C. Memo. 2008-60 UNITED STATES TAX COURT DAN PICKELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14400-07. Filed March 11, 2008. Dan Pickell, pro se. Kaelyn Romey, for respondent. MEMORANDUM OPINION HAINES, Judge: This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction under Rule 53 and petitioner’s motion to restrain collection under Rule 55.1 Respondent moves to dismiss on the ground that no notice of 1Unless otherwise indicated, section references are to the (continued...)Page: 1 2 3 4 5 6 NextLast modified: March 27, 2008