BELLIS v. COMMISSIONER

Docket No. 9715-88.

57 T.C.M. 667 (1989)

T.C. Memo. 1989-277

Gordon and Cathy Bellis v. Commissioner.

United States Tax Court.

Filed June 8, 1989.


Attorney(s) appearing for the Case

Edward B. Simpson, John Gigounas, 50 California St., San Francisco, Calif., and James Booher, for the petitioners. Ann M. Murphy, for the respondent.


Memorandum Opinion

GERBER, Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. We held a hearing on the motion on December 9, 1988, and received stipulations, testimony and exhibits. The findings of fact and opinion are combined for simplicity. For purposes of this opinion, petitioners will refer to Gordon and Cathy Bellis, although petitioner Cathy Bellis died after their petition was filed. All section references...

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