Thomas Gerald Roots and Linda Vesta Roots - Page 1
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T.C. Memo. 1999-88
UNITED STATES TAX COURT
THOMAS GERALD ROOTS AND LINDA VESTA ROOTS, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14438-98. Filed March 23, 1999.
Petitioners move to dismiss for lack of
jurisdiction on the grounds that (1) the primary
adjustment in the notice of deficiency is wrong and (2)
the period of limitations on assessment expired before
the notice of deficiency was issued.
1. Held: Neither of these matters goes to the
jurisdiction of this Court, and so petitioners' motion
to dismiss is denied.
2. Held, further, treating petitioners' motion as
a motion for summary judgment on the limitations
question, there is a genuine issue of material fact (a
dispute about whether petitioners' purported signatures
on a Form 872 are genuine), and so petitioners are not
entitled to summary judgment.
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