Andrea Pappas - Page 4

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          2002, trial date.  By order dated March 11, 2002, the Court                 
          granted petitioner’s motion for a continuance, retained                     
          jurisdiction, and ordered the parties to file a status report on            
          or before May 10, 2002.                                                     
               On May 10, 2002, respondent filed a status report with the             
          Court, expressing a concern that the Court may lack jurisdiction            
          in this case.  Respondent’s status report stated that the                   
          National Office of the Internal Revenue Service was reviewing the           
          matter and that respondent subsequently expected to file a motion           
          to dismiss for lack of jurisdiction.                                        
               On May 16, 2002, respondent filed a Motion to Dismiss for              
          Lack of Jurisdiction on the ground that the notice of deficiency            
          is invalid because respondent did not determine a “deficiency”              
          within the meaning of sections 6211 and 6665.  On May 21, 2002,             
          the Court ordered petitioner to file an objection, if any, to               
          respondent’s motion to dismiss on or before June 21, 2002.                  
               On June 19, 2002, petitioner filed an objection to                     
          respondent’s motion to dismiss.  On September 9, 2002, pursuant             
          to an order of the Court, respondent’s motion was called for                
          hearing at the Court’s trial session in New York, New York.                 
               Upon the basis of the record, we summarize the facts as                
          follows.  Sometime in January 1997, petitioner filed her 1993               
          Form 1040, U.S. Individual Income Tax Return.  Petitioner                   
          reported no income tax liability on the 1993 tax return.                    






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