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PHILIPS v. COMMISSIONER

Docket No. 5057-96.

72 T.C.M. 109 (1996)

T.C. Memo. 1996-319

Scott R. Philips v. Commissioner.

United States Tax Court.

Filed July 15, 1996.

Attorney(s) appearing for the Case

Scott R. Philips, pro se. Michael H. Salama, for the respondent.

MEMORANDUM OPINION

NAMEROFF, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(4)1 and Rules 180, 181, and 183. This case is before us on respondent's Motion to Dismiss for Failure to State A Claim and to Impose a Penalty Under Section 6673, filed pursuant to Rule 40. The Court, sua sponte, also considers whether to strike portions of the petition under Rule 52.

Respondent determined...

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