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SONIER v. COMMISSIONER

Docket No. 13527-98R.

78 T.C.M. 313 (1999)

T.C. Memo. 1999-275

Frank A. Sonier v. Commissioner.

United States Tax Court.

Filed August 17, 1999.

Attorney(s) appearing for the Case

Frank A. Sonier, pro se. Lawrence H. Ackerman, for the respondent.

MEMORANDUM OPINION

DEAN, Special Trial Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. The issues for decision are: (1) Whether petitioner has alleged that there is an actual controversy; and (2) whether petitioner is an "interested party" entitled to file a petition for declaratory judgment pursuant to section 7476(b)(1)1 with respect to the continuing qualification of the Maritime...

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