9
distinguishable from the facts here, and, therefore, the holding
does not apply. Moreover, petitioner actually received the
notices of deficiency on September 23, 1995. We find that the
conditions of section 6212(a) were satisfied.
Petitioner's motion to vacate the granting of respondent's
Motion to Dismiss for Lack of Jurisdiction and to Strike as to
the Taxable Years 1991, 1992, 1993, and 1994 is denied.
To reflect the foregoing,
An appropriate order
will be issued.
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