15
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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