- 8 - paragraph (i) of the explanation of adjustments. In particular, respondent admits that the second sentence should have read: "On October 17, 1990, James R. Rickman directed the First Union Brokerage Services of North Carolina to transfer two U.S. Treasury Notes totalling $300,000 to Kaye Rickman, Janet Tipton and James Tipton." (Emphasis added.) In response to the notice of deficiency, petitioner filed a timely petition for redetermination with this Court. Shortly after respondent filed her answer to the petition, the parties became embroiled in both a discovery dispute and a disagreement over whether either party should be granted leave to file an amendment to their initial pleading. A hearing was scheduled in Washington, D.C., on June 28, 1995, for the purpose of resolving five pending motions stemming from these particular disputes. On the eve of this hearing, petitioner filed both a Motion to Dismiss for Lack of Jurisdiction and a Motion for Summary Judgment.4 In the meantime, by letter dated June 22, 1995, Doris K. Rickman wrote to the Internal Revenue Service District Director in Greensboro, North Carolina, and requested a written statement pursuant to section 7517 explaining the property valuations 4 Although the June 28, 1995, hearing was conducted as scheduled, the Court decided to reserve ruling on the various collateral matters in dispute in favor of first ruling on the jurisdictional issue raised in petitioner's motion to dismiss.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011