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SMITH v. COMMISSIONER

Docket Nos. 30189-89, 30366-89.

96 T.C. 10 (1991)

STEPHEN L. SMITH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT HEATHER M. SMITH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 15, 1991.

Attorney(s) appearing for the Case

J. Montjoy Trimble, for the petitioner in docket No. 30189-89.

Robert L. Doyel, for the petitioner in docket No. 30366-89.

Charles A. Baer, for the respondent.

OPINION

NIMS, Chief Judge:

This matter is before the Court on petitioner Stephen L. Smith's motion to stay the proceedings. For reasons hereinafter stated, the Court has found it necessary to raise sua sponte the question of whether the Court has jurisdiction over the petition filed by Stephen L. Smith. (Unless otherwise indicated, section references are to the Internal Revenue Code as in effect during the years in issue.)

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