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B. John Williams Jr., Carolyn O. Ward, and Miriam L. Fisher,
for petitioners.
Stephen M. Miller and Nancy W. Hale, for respondent.
OPINION
RUWE, Judge: This case was assigned to Special Trial Judge
Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) 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
ARMEN, Special Trial Judge: These cases are before the
Court on (1) respondent's Motion to Dismiss for Lack of
Jurisdiction and to Strike as to Interest Due From the
Petitioner, filed in docket No. 23670-95; and (2) respondent's
Motion to Dismiss for Lack of Jurisdiction and to Strike as to
the Taxable Year 1989 and as to Interest Due From the Petitioner,
filed in docket No. 23672-95.
As explained in greater detail below, the issue for decision
is whether the Court has jurisdiction to redetermine petitioners'
liability for interest computed at the increased rate established
1Unless otherwise indicated, all section, chapter, and
subtitle references are to the Internal Revenue Code in effect
for the taxable years in issue, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
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