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HALPERN v. COMMISSIONER

Docket No. 14384-90.

96 T.C. 895 (1991)

RONALD B. & SUZANNE KAY HALPERN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 24, 1991.

Attorney(s) appearing for the Case

Peter Driscoll, for the petitioners.

Joseph T. Chalhoub, for the respondent.

OPINION

NIMS, Chief Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. For reasons hereinafter stated, we now find it necessary to raise sua sponte the question of whether the Court has jurisdiction over the petition filed in this case. (Unless otherwise indicated, section references are to the Internal Revenue Code as in effect for the year in issue.)

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