Robert G. Honts - Page 15

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            than two separate notices in these circumstances where the tax                                 
            years were intertwined.                                                                        
                  Based on the foregoing, we will grant petitioner's motion to                             
            dismiss for lack of jurisdiction and deny respondent's motion to                               
            dismiss for lack of jurisdiction.6                                                             
                  An appropriate order and order of                                                        
            dismissal for lack of jurisdiction                                                             
            will be entered.                                                                               
























            6                                                                                              
                  Petitioner has requested leave to file a motion for an award                             
            of attorneys' fees, costs, and other expenses, pursuant to sec.                                
            7430.  Should petitioner desire to pursue this matter, he must                                 
            comply with Rules 230 and 231.                                                                 




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