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FEARS v. COMMISSIONER

Docket No. 21508-05.

129 T.C. 8 (2007)

129 T.C. No. 2

GARY R. FEARS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 2, 2007.

Attorney(s) appearing for the Case

Anthony G. Tumminello, for petitioner.

John J. Boyle, for respondent.

OPINION

FOLEY, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction and to strike. The issue for decision is whether the Court has jurisdiction to determine whether petitioner is liable for section 6662(a) and (h)1 penalties relating to 2001.

Background

On October 27, 2000, Gateway Investment Partners (Gateway) was formed. GF Gateway Investments LLC...

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