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TIPTON AND KALMBACH, INC. v. COMMISSIONER

Docket No. 21088-81R.

43 T.C.M. 1345 (1982)

T.C. Memo. 1982-260

Tipton and Kalmbach, Inc. v. Commissioner.

United States Tax Court.

Filed May 11, 1982.

Attorney(s) appearing for the Case

James H. Turner and Stephen A. Weinstein, 818 7th St., Denver, Colo., for the petitioner Samuel E. Berger, for the respondent.

Memorandum Opinion

DAWSON, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction on the ground that petitioner has failed to exhaust its administrative remedies as required by section 7476(b)(3)1 and Rule 210(c)(4).2 Respondent filed a memorandum in support of his motion and petitioner filed two memoranda in opposition thereto. The motion was heard at the...

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