- 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 failurePage: 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