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MARC v. COMMISSIONER

Dkt. No. 14688-06.

94 T.C.M. 612 (2007)

T.C. Memo. 2007-374

Marc and Sherri Ward v. Commissioner.

United States Tax Court.

December 26, 2007.

Attorney(s) appearing for the Case

Eugene A. Steger, Jr., for petitioners.

Harry J. Negro, for respondent.

MEMORANDUM OPINION

GALE, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction.1 In his motion, respondent contends that no notice was issued to petitioners upon which to form the basis for a petition to this Court. Petitioners filed a response, and the Court conducted a hearing on the matter.

Background

At the time their petition was filed, petitioners resided...

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