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UNIVERSAL TRUST 06-15-90 v. COMMISSIONER

Docket No. 3885-98.

80 T.C.M. 925 (2000)

T.C. Memo. 2000-390

Universal Trust 06-15-90, Four WS TT01, Trustee v. Commissioner.

United States Tax Court.

Filed December 27, 2000.

Attorney(s) appearing for the Case

Jimmy C. Chisum, for the petitioner.1 Nicholas J. Richards and Miles D. Friedman, for the respondent.

MEMORANDUM OPINION

BEGHE, Judge:

This case is before the Court on the parties' cross-motions to dismiss for lack of jurisdiction. Petitioner asserts we must dismiss because respondent failed to determine a deficiency in petitioner's tax, as required by section 62122 and Scar v. Commissioner [87-1 USTC ¶ 9277], 814 F.2d 1363 (9th Cir. 1987...

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