- 7 - for Lack of Jurisdiction on the ground that petitioner lacks the capacity under Rule 60(c) to invoke this Court's jurisdiction.3 To reflect the foregoing, An order granting respondent's Motion to Dismiss for Lack of Jurisdiction will be entered. 3 We note that petitioner's tax liabilities may still be litigated on the merits in this Court in the event respondent later issues notice of transferee liability to the appropriate persons. Sec. 6901; Great Falls Bonding Agency, Inc. v. Commissioner, 63 T.C. 304, 307 (1974).Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011