- 7 -
dispute respecting the applicability of the period of limitations
is the subject of the parties' cross-motions for summary judgment
filed in docket No. 14781-96.
Second Notice of Deficiency
By letter dated December 13, 1996, respondent notified
Hibiscus that respondent would deal directly with petitioner
respecting the latter's tax liabilities for the years 1988, 1989,
1990, and 1991. In addition, on December 30, 1996, respondent
issued a further notice of deficiency to petitioner determining
deficiencies in petitioner's Federal income taxes for the years
and in the amounts as follows:
Year Deficiency
1989 $2,932,321
1990 4,591,187
1991 5,658,791
Petitioner filed a timely petition for redetermination
(assigned docket No. 5898-97) with respect to the second notice
of deficiency. Shortly thereafter, however, petitioner filed a
motion to dismiss for lack of jurisdiction asserting that the
December 30, 1996, notice of deficiency constitutes an improper
second notice under section 6212(c). Respondent filed a response
to petitioner's motion to dismiss stating that the December 30,
1996, notice of deficiency was issued as a protective measure out
of concern that the Court might hold the April 11, 1996, notice
of deficiency to be invalid on the basis of respondent's failure
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011