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HURFORD v. COMMISSIONER

Docket No. 13278-01L.

83 T.C.M. 1467 (2002)

T.C. Memo. 2002-94

Robert Hurford and Catherine Simone Hale v. Commissioner.

United States Tax Court.

Filed April 8, 2002.

Attorney(s) appearing for the Case

Robert Hurford and Catherine Simone Hale, pro sese.

Robin Ferguson, for the respondent.

MEMORANDUM OPINION

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on: (1) Respondent's oral motion to dismiss for lack of jurisdiction and to strike all allegations in the second amended petition pertaining to a Notice of Federal Tax Lien filed October 8, 1998, pertaining to a frivolous return penalty imposed against petitioners pursuant to section 6702; and (2) respondent's motion to dismiss for failure to state a claim and to impose...

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