SOWARD v. COMMISSIONER

Docket No. 15652-05.

92 T.C.M. 475 (2006)

T.C. Memo. 2006-262

David Soward v. Commissioner.

United States Tax Court.

December 11, 2006.


Attorney(s) appearing for the Case

Martin A. Schainbaum and Esther W. Chang, for petitioner.

Gerald A. Thorpe and Paul R. Zamolo, for respondent.


MEMORANDUM OPINION

COHEN, Judge.

This case is before us on respondent's motion to dismiss for lack of jurisdiction on the ground that the notice of deficiency is invalid and prohibited by section 6225. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.

Background

Petitioner resided in San Francisco, California, at the time that he filed his petition.

A Notice...

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