- 2 - and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE DEAN, Special Trial Judge: On March 24, 1995, respondent filed a motion to dismiss for lack of jurisdiction upon the ground that under Tax Court Rule 60(c) petitioner, Pasadena ENT Clinic, P.A. (ENT Clinic), lacks the legal capacity to engage in litigation before the Court. Petitioner filed an opposition to respondent's motion on May 15, 1995. The Court set a hearing on the motion at the September 5, 1995, Houston, Texas, trial session. At the trial session, the parties appeared through counsel, argued the motion, and filed a stipulation of facts. After the hearing on respondent's motion to dismiss, petitioner filed on November 1, 1995, a Motion to Reopen Record to Receive Additional Evidence, and on November 15, 1995, a Motion to Stay Proceedings. Respondent filed objections to both motions and petitioner filed responses to each of respondent's objections. Background For calendar years 1990 and 1991, ENT Clinic filed Forms 1120, U.S. Corporation Income Tax Return. On September 16, 1994, 1Unless otherwise indicated, all section references are to the Internal Revenue Code as amended. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011