KEETON v. COMMISSIONER

Docket No. 7955-77.

74 T.C. 377 (1980)

ROY KEETON AND SHIRLEY K. KEETON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 21, 1980.


Attorney(s) appearing for the Case

Gerald W. Dykes, for the petitioners.

Bernard B. Kornmehl and Elizabeth DePriest, for the respondent.


OPINION

DAWSON, Judge:

This case was assigned to and heard by Special Trial Judge Francis J. Cantrel for the purpose of conducting the hearing and ruling on respondent's motion to dismiss for lack of jurisdiction and petitioners' cross-motion to dismiss for lack of jurisdiction. After a review of the record, we agree with and adopt his opinion which is set forth below.1

OPINION OF THE SPECIAL TRIAL JUDGE

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