KELLOGG v. COMMISSIONER

Docket No. 11208-86.

88 T.C. 167 (1987)

BURTON KELLOGG, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 15, 1987.


Attorney(s) appearing for the Case

Anthony E. Reiss, for the petitioner.

Anne M. DiFonzo and Charles Williams, for the respondent.


OPINION

FEATHERSTON, Judge:

Respondent's motion to dismiss for lack of jurisdiction filed herein was assigned to Special Trial Judge Francis J. Cantrel pursuant to section 7456(d)(4) (redesignated section 7443A(b)(4) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 1755) and Rule 180.1 After a review of the record, we agree with and adopt his opinion which is set forth below.

OPINION OF...

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