- 2 -
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's Motion to Dismiss For Lack of
Jurisdiction. The issue for decision is whether petitioner has
the capacity to file a petition for redetermination with this
Court.
Background
On May 10, 1995, respondent issued three separate notices of
deficiency to B. Joe Rosa, Jr., An Accountancy Corporation
(petitioner), determining deficiencies in, additions to, and
penalties in respect of its Federal income taxes as follows:
Tax Additions to Tax and Penalties
Year Sec. Sec. Sec. Sec.
Ended Deficiency 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)(1) 6663(a)
6/30/87 $30,092 $23,176 50% of the in- --- ---
terest due on
the deficiency
12/31/87 9,163 --- --- $6,872 ---
12/31/88 30,414 --- --- 22,811 ---
12/31/89 37,630 --- --- --- $28,223
12/31/90 41,595 --- --- --- 31,196
12/31/91 38,502 --- --- --- 28,881
On November 3, 1995, B. Joe Rosa, Jr., filed a petition on behalf
of petitioner contesting the notices of deficiency described
above. The first paragraph of the petition states that
petitioner is a "defunct Professional Corporation".
(...continued)
Procedure.
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