PARLIN v. COMMISSIONER

Dkt. No. 4904-05.

91 T.C.M. 715 (2006)

T.C. Memo. 2006-18

Kimberley A. Parlin v. Commissioner.

United States Tax Court.

February 6, 2006.


Attorney(s) appearing for the Case

Stephen K. Midgley, for petitioner.

Louise R. Forbes, for respondent.


MEMORANDUM OPINION

THORNTON, Judge.

This case is before us on respondent's motion to dismiss for lack of jurisdiction. For the reasons stated below, we must grant respondent's motion.

Background

On February 11, 2004, petitioner executed Form 2848, Power of Attorney and Declaration of Representative, appointing Stephen K. Midgley (Mr. Midgley) as her attorney in fact. The Form 2848 states that "Original notices and other written communications...

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