DaBoul v. Commissioner (429 F.2d 38, 1970)

PER CURIAM:

The appeal is dismissed as legally frivolous.

The issuance of a statutory notice of deficiency by the commissioner (which was never issued in this case) is necessary before the tax court has jurisdiction. See Corbett v. Frank, 9 Cir., 293 F.2d 501.

If DaBoul was entitled to any relief, he should have proceeded in some United States district court.