United States Tax Court December 2, 1981, Docket No. 750-81R (Shut Out Dee-Fence, Inc. v. Commissioner)

lead-opinion

OPINION

Dawson, Judge:

This case was assigned to Special Trial Judge Francis J. Cantrel for the purpose of conducting the hearing and ruling on respondent’s motion to dismiss for lack of jurisdiction. After a review of the record, we agree with and adopt his opinion which is set forth below.