RUSTAM v. COMMISSIONER

Dkt. No. 3316-04L.

89 T.C.M. 829 (2005)

T.C. Memo. 2005-42

Mardi Rustam v. Commissioner.

United States Tax Court.

March 7, 2005.


Attorney(s) appearing for the Case

Stephen M. Lopez, for petitioner;

John D. Faucher, for respondent.


MEMORANDUM OPINION

WELLS, Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction and petitioner's motion for award of reasonable litigation costs.1 Unless otherwise noted, 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

At the time of filing his petition...

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