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and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: These cases are before the
Court on respondent's Motions to Dismiss for Lack of Jurisdiction
and petitioner's Motions to Restrain Assessment, Levy, Lien, and
Collection, as supplemented. The principal issue for decision is
whether the Court has jurisdiction over the petitions filed in
these cases.
Background
On June 23, 1995, respondent issued a notice of deficiency
to petitioner in which respondent determined deficiencies in and
additions to petitioner's Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1989 $54,253 $9,608 $2,173
1990 58,904 9,321 2,884
1991 59,836 9,796 2,425
Also on June 23, 1995, respondent issued a separate notice
of deficiency to petitioner in which respondent determined a
deficiency in petitioner's Federal income tax for 1992 in the
amount of $42,608 and additions to tax under sections 6651(a) and
6654(a) in the amounts of $6,901 and $1,122, respectively. Both
notices of deficiency were addressed to petitioner at 6001 Knight
(...continued)
and Procedure.
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