Lone Star Life Insurance Company - Page 7

                                        - 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