WILLIAMS v. COMMISSIONER

No. 2202-08.

131 T.C. 54 (2008)

JOSEPH B. WILLIAMS, III, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 2, 2008.


Attorney(s) appearing for the Case

David H. Dickieson, for petitioner.

John C. McDougal, for respondent.


OPINION

GUSTAFSON, Judge:

This matter is before us on respondent's "Motion To Dismiss for Lack of Jurisdiction and To Strike as to the Taxable Year 2001, as to Interest, and as to FBAR [foreign bank account report] Penalties" (the motion). Petitioner objects (the objection). We shall grant the motion.

Background

By notice of deficiency dated October 29, 2007, respondent determined deficiencies in petitioner's 1993 through...

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