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DYNAMIC ENERGY, INC. v. COMMISSIONER

Docket No. 3539-90.

98 T.C. 48 (1992)

DYNAMIC ENERGY, INC., STEPHANIE M. HAGGERTY, F.K.A. STEPHANIE M. DELAMBERT, A PERSON OTHER THAN THE TAX MATTERS PERSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 21, 1992.

Attorney(s) appearing for the Case

Kevin R. Armbruster and W. Hampton Morris, for petitioner.

Timothy S. Sinnott and Jeffrey I. Rosenberg, for respondent.

OPINION

NIMS, Chief Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction and to strike as to section 6013(e). (Unless otherwise indicated, section references are to the Internal Revenue Code as in effect for 1984. Rule references are to the Tax Court Rules of Practice and Procedure.)

Background

Dynamic Energy, Inc. (Dynamic), is a subchapter S corporation subject to the S corporation...

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