Mary Ann Whitacre - Page 3




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               This matter is before the Court on respondent’s Motion To              
          Dismiss For Lack Of Jurisdiction, as supplemented.  Respondent              
          contends that this case should be dismissed for lack of                     
          jurisdiction “as the petition requests review of Respondent’s               
          determination denying relief from liability based upon the                  
          provisions of I.R.C. � 66(c).”  As explained in detail below, we            
          shall grant respondent’s motion, as supplemented.                           
          Background                                                                  
               The record establishes and/or the parties do not dispute the           
          following:                                                                  
               A.  Petitioner and Mr. Sonnabend                                       
               At the time that her petition was filed with the Court, and            
          at all other times relevant to this case, petitioner resided in             
          Dallas, Texas.  As a resident of Texas, petitioner is subject to            
          the community property laws of that State.                                  
               For a period of time, petitioner was married to Henry                  
          Sonnabend (Mr. Sonnabend), a certified public accountant and                
          senior regional partner with Ernst and Young.  Like petitioner,             
          Mr. Sonnabend was a resident of Texas at all relevant times and             
          subject to the community property laws of that State.                       
               Prior to the taxable year 1995, petitioner and Mr. Sonnabend           
          selected as their annual accounting period a fiscal year ending             
          June 30.  Accordingly, petitioner’s taxable year 1995 includes              
          the period from July 1, 1994 through June 30, 1995.                         






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