- 2 -
Held further: We lack jurisdiction under sec.
6404(g) since, under these circumstances, the notice of
deficiency issued to Ps does not constitute a notice of
the Secretary's final determination not to abate
interest.
Robert E. Kovacevich, for petitioners.
Michelle K. Loesch and Pamela Wilson Fuller, for respondent.
OPINION
COHEN, Chief Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos, pursuant to the provisions of
section 7443A(b)(4).1 The Court agrees with and adopts the
opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's Motion to Dismiss for Lack of
Jurisdiction and to Strike With Respect to Penalties and
Interest. As explained in greater detail below, we shall grant
respondent's motion.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code as amended. Rule references are to the Tax
Court Rules of Practice and Procedure.
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