STORELLI v. COMMISSIONER

Docket No. 32228-85.

86 T.C. 443 (1986)

GEORGE S. STORELLI AND JILL STORELLI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 24, 1986.


Attorney(s) appearing for the Case

Jan S. Neiman, for the petitioners.

John F. Hernandez and Will E. McLeod, for the respondent.


OPINION

DRENNEN, Judge:

Respondent's motion to dismiss for lack of jurisdiction filed herein was assigned to Special Trial Judge Francis J. Cantrel for hearing, consideration, and ruling thereon.1 After a review of the record, we agree with and adopt his opinion which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

CANTREL, Special Trial Judge:

This case is before the Court on respondent...

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