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Barbara B. Franklin, for respondent.
MEMORANDUM OPINION
COHEN, Chief Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos, pursuant to the provisions of
section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's Motion to Dismiss for Lack of
Jurisdiction. Respondent contends that the Court lacks
jurisdiction under section 6404(g) to consider the petition filed
in this case. As explained in greater detail below, we will
grant respondent's motion.
Background
On or about May 28, 1997, petitioners filed with respondent
a Form 843, Claim for Refund and Request for Abatement,
requesting that respondent abate interest for the taxable year
1992 in excess of $172,000. On November 26, 1997, after several
months passed with no response from respondent, petitioners wrote
to Nancy Givens (Ms. Givens) at respondent's Problems Resolution
1 Section references are to the Internal Revenue Code, as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure.
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