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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.
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