- 6 -
As a final matter, we turn to petitioner's motions to
restrain assessment and collection. Section 6213(a) provides
that the Tax Court may enjoin assessment or collection if the
Commissioner is attempting to assess or collect amounts that have
been placed in dispute in a timely-filed petition for
redetermination. Powerstein v. Commissioner, 99 T.C. 466, 471-
472 (1992); Powell v. Commissioner, 96 T.C. 707, 711 (1991). The
record reflects that the amounts that respondent has assessed and
is attempting to collect relate to petitioner's tax liability for
1989, 1990, 1991, 1992. As a consequence of our holding that we
lack jurisdiction over those years, it follows that we lack
jurisdiction to enjoin assessment and collection. Powell v.
Commissioner, supra. Accordingly, we will deny petitioner's
motions for lack of jurisdiction.
To reflect the foregoing,
Appropirate orders granting
respondent's motions, denying petitioner's
motions, and dismissing these cases for
lack of jurisdiction will be entered.
Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011