HUNTER v. COMMISSIONER

Docket No. 1397-05.

90 T.C.M. 300 (2005)

T.C. Memo. 2005-219

John Erwin Hunter II and Alma Esteban Hunter v. Commissioner.

United States Tax Court.

September 20, 2005.


Attorney(s) appearing for the Case

John Erwin Hunter II and Alma Esteban Hunter, pro sese.

A. Gary Begun, for respondent.


MEMORANDUM OPINION

LARO, Judge:

This matter is before the Court on respondent's motion to dismiss for failure to state a claim upon which relief may be granted. All section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Background

On December 2, 2004, respondent issued a notice of deficiency in which respondent determined a $131,093 deficiency...

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