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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011