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On June 10, 1996, respondent issued a notice of intent to
levy to petitioner and Charles N. Scott demanding payment of
$3,948.29 in satisfaction of their tax liability for 1993.
Respondent subsequently filed a motion to dismiss for lack
of jurisdiction asserting that the notice of deficiency issued to
petitioner for 1992 is invalid on the ground that it was not
mailed to petitioner's last known address. Petitioner filed an
objection to respondent's motion to dismiss asserting that the
taxable years in dispute are 1992 and 1993 and that the notices
of deficiency for those years are invalid on the ground that they
have "no basis in material fact". Petitioner also filed a motion
to restrain assessment and collection.
Respondent maintains that the Court has no jurisdiction to
consider the validity of the notice of deficiency issued to
petitioner and Charles N. Scott for 1993 because the 1993 taxable
year was not placed in dispute in the petition.
This matter was called for hearing in Washington, D.C., at a
motions session of the Court. Counsel for respondent appeared at
the hearing and presented argument on the pending motions.
Although petitioner did not appear at the hearing, she did file a
written statement with the Court pursuant to Rule 50(c).
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Last modified: May 25, 2011