Duane E. Hudspath - Page 3

                                        - 3 -                                         
          notice of deficiency that included adjustments relating to                  
          partnership items.                                                          
               In response to the FPAAs, Jimmy C. Chisum, on July 17, 2000,           
          initiated a single partnership-level proceeding, Stephens City              
          Chiropractic, PLC v. Commissioner, docket No. 7982-00.  On April            
          2, 2001, this Court dismissed the partnership-level proceeding              
          for lack of jurisdiction on the ground that Mr. Chisum failed to            
          establish his capacity to act on behalf of the entities.3  On               
          July 1, 2001, the decision in the partnership-level proceeding              
          became final.                                                               
               In response to the notice of deficiency, petitioner, on July           
          14, 2000, initiated a partner-level proceeding, Hudspath v.                 
          Commissioner, docket No. 7901-00.  On December 7, 2001, this                
          Court granted respondent’s motion to dismiss for lack of                    
          jurisdiction and to strike the portion of the partner-level                 
          proceeding relating to partnership items on the ground that                 
          respondent had sent petitioner, pursuant to section 6225, a                 
          notice of deficiency prior to the completion of the partnership-            
          level proceeding.                                                           





               3  Mr. Chisum has initiated several proceedings that this              
          Court has dismissed on similar grounds.  E.g., Universal Trust              
          06-15-90 v. Commissioner, T.C. Memo. 2000-390; Banana Moon Trust            
          v. Commissioner, T.C. Memo. 2000-73; Jeff Burger Prods., LLC v.             
          Commissioner, T.C. Memo. 2000-72.                                           




Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011