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PADRE ISLAND THUNDERBIRD, INC. v. COMMISSIONER

Docket No. 245-78.

72 T.C. 391 (1979)

PADRE ISLAND THUNDERBIRD, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 4, 1979.

Attorney(s) appearing for the Case

Donald S. Carnow, for the petitioner.

Harmon B. Dow, for the respondent.

OPINION

SIMPSON, Judge:

This case is before us on the Commissioner's motion to dismiss for lack of jurisdiction on the ground that the petitioner lacks the capacity to litigate before this Court under Rule 60(c), Tax Court Rules of Practice and Procedure, and on the petitioner's cross-motion for judgment on the pleadings on the ground that the deficiency notice was not proper because it was sent to a dissolved...

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