B. Joe Rosa, Jr. An Accountancy Coproration - Page 7

                                        - 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