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income tax in the amount of $1,486 and an addition to tax in the
amount of $2,688.67, pursuant to section 6651(a)(1) for the tax
year 1990.
On August 6, 1996, petitioner filed a petition for
redetermination of the deficiency determined by respondent in the
notice of deficiency dated May 9, 1996. Petitioner further
requested that the Court assume jurisdiction of the taxable years
1991, 1992, 1993, and 1994, and determine that there are no
deficiencies or additions and/or penalties owing for those years.
The 30-day letter was attached to the petition.
On October 2, 1996, respondent filed a Motion to Dismiss for
Lack of Jurisdiction and to Strike the Taxable Years 1991, 1992,
1993, and 1994. Respondent moved to dismiss as to the taxable
years 1991, 1992, and 1993, upon the ground that the petition was
not filed within the time prescribed in sections 6213(a) and 7502
and as to the taxable year 1994 upon the ground that no notice of
deficiency had been issued as to that year. The Court notified
petitioner that an objection to respondent's motion had to be
filed on or before October 22, 1996. Petitioner did not file a
timely objection. On November 5, 1996, the Court granted
respondent's motion to dismiss as to the taxable years 1991,
1992, 1993, and 1994, and all references to these years were
stricken from the petition.
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