Jack Alban Koerner - Page 2

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            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 and petitioner's Motion To Restrain Assessment and                           
            Collection.  The primary issue for decision is whether the Court                          
            has jurisdiction over the petition filed in this case.                                    
            Background                                                                                
                  Petitioner did not file tax returns for the taxable years                           
            1987 through 1993.  However, during the period 1989 through 1995,                         
            petitioner sent a substantial amount of correspondence to various                         
            Internal Revenue Service (IRS) offices concerning his tax                                 
            liabilities for 1987 and subsequent years.  Through mid-1995,                             
            petitioner consistently listed his address on this correspondence                         
            as 6627 Christy Acres Circle, Mt. Airy, Maryland (the Mt. Airy                            
            address).                                                                                 
                  On November 1, 1993, respondent mailed a notice of                                  
            deficiency to petitioner determining a deficiency in his Federal                          
            income tax for 1990 in the amount of $8,481 and additions to tax                          
            under sections 6651(a) and 6654(a) in the amounts of $2,120.25                            


            (...continued)                                                                            
            in effect for the years in issue, unless otherwise indicated.                             
            All Rule references are to the Tax Court Rules of Practice and                            
            Procedure.                                                                                




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