- 6 - deficiency for 1991. Because respondent was not prohibited from issuing the notice of deficiency in this case and petitioner timely petitioned for a redetermination, we have jurisdiction to consider and resolve the parties' controversy for all years, including 1991.4 To reflect the foregoing, An order will be issued granting respondent's motion for partial summary judgment. 4 In the consolidated case filed in response to the February notice, respondent moved to amend the answer to allege that the 1991 excise tax be considered along with the 1991 income tax deficiency in that case. Respondent, it appears, moved to include the excise tax in the consolidated case if the partial summary judgment motion was unsuccessful. Due to the granting of respondent's partial summary judgment motion, respondent's motion to amend the answer in the consolidated case will be denied.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011