SIGEL v. COMMISSIONER

KENNETH J. SIGEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

SIGEL v. COMMISSIONER

No. 1851-00

United States Tax Court

T.C. Memo 2001-138; 2001 Tax Ct. Memo LEXIS 166; 81 T.C.M. (CCH) 1743;

June 12, 2001, Filed

An order will be entered granting respondent's motion to dismiss for lack of jurisdiction.

Kenneth J. Sigel, pro se.

Frederick Petrino, for respondent.

Swift, Stephen J.

SWIFT

MEMORANDUM OPINION

SWIFT, JUDGE: This case is before us on respondent's motion to dismiss. The issue presented is whether we lack jurisdiction over petitioner's claims that an addition to tax under section…