Legal Opinion

Harwood v. Commissioner

United States Tax Court

Decided February 14, 1979No. Docket No. 1424-78Unpublished

1Opinion of the Court

NATHANAEL AND JANE R. HARWOOD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Harwood v. Commissioner

Docket No. 1424-78.

United States Tax Court

T.C. Memo 1979-54; 1979 Tax Ct. Memo LEXIS 471; 38 T.C.M. (CCH) 219; T.C.M. (RIA) 79054;

February 14, 1979, Filed

Michael G. West, for the petitioners.

John O. Tannenbaum, for the respondent.

DAWSON

MEMORANDUM OPINION

DAWSON, Judge: This motion to dismiss for lack of jurisdiction was assigned to and heard by Special Trial Judge Murray H. Falk. The Court agrees with and adopts his opinion which is set forth below. 1

OPINION OF THE SPECIAL TRIAL…

2Cases cited10 opinions

  1. Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
  2. Moffat v. CommissionerUnited States Tax Court · 1966
  3. Sylvan v. CommissionerUnited States Tax Court · 1975
  4. James E. Shipley and Patricia B. Shipley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
  5. Hays Corp. v. CommissionerUnited States Tax Court · 1963

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