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POWELL v. COMMISSIONER

Docket No. 10560-96.

74 T.C.M. 1424 (1997)

T.C. Memo. 1997-560

William L. and Mary Lee Powell v. Commissioner.

United States Tax Court.

Filed December 22, 1997.

Attorney(s) appearing for the Case

Valentine C. Crotin, for the petitioners. Alvin A. Ohm and Andrew M. Winkler, for the respondent.

MEMORANDUM OPINION

GOLDBERG, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction. The issue raised by respondent's motion to dismiss involves the scope of the Court's jurisdiction in an affected-items proceeding.

Some of the facts have been stipulated and are so found. The stipulation...

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