BAXTER v. COMMISSIONER

Docket No. 7177-00L.

82 T.C.M. 897 (2001)

T.C. Memo. 2001-300

Robert Baxter v. Commissioner.

United States Tax Court.

Filed November 13, 2001.


Attorney(s) appearing for the Case

Robert Baxter, pro se. John Y. Chinnapongse, for the respondent.


MEMORANDUM OPINION

DINAN, Special Trial Judge:

This case was called from the calendar of the trial session at San Francisco, California, on January 22, 2001, for hearing on respondent's Motion to Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted, filed November 6, 2000, and petitioner's Notice of Objection, filed December 4, 2000. The parties appeared and were heard.

Background

In a statutory notice of deficiency...

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