PHOTO ART MARKETING TRUST v. COMMISSIONER

Docket No. 20582-98.

79 T.C.M. 1571 (2000)

T.C. Memo. 2000-65

Photo Art Marketing Trust, John P. Wilde, Co-Trustee, and Photo Art Publishing Trust, John P. Wilde, Co-Trustee v. Commissioner.

United States Tax Court.

Filed February 29, 2000.


Attorney(s) appearing for the Case

John P. Wilde, for the petitioners. David W. Otto and Doreen M. Susi, for the respondent.


MEMORANDUM OPINION

CHIECHI, Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction (respondent's motion). We shall grant respondent's motion.

Background

For purposes of respondent's motion, the parties do not dispute the following factual allegations that are part of the record. At all relevant times, each petitioner was a trust organized under the laws of the State of Arizona and was engaged...

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