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petitioner lacks capacity under Rule 60(c) to invoke this Court's
jurisdiction.
Background
Hanna & Associates, P.C., formerly Mark J. Hanna, P.C. was a
corporation organized under the laws of the State of Texas. On
February 2, 1994, Mark J. Hanna, petitioner's sole shareholder,
adopted a resolution to dissolve the corporation. On February
24, 1994, petitioner filed a certificate of dissolution with the
Texas secretary of state resulting in petitioner's dissolution
pursuant to Tex. Bus. Corp. Act Ann. art. 6.06 (West 1994).
Petitioner's 1993 and 1994 Federal income tax returns were
filed on March 15, 1994, and September 18, 1995, respectively.
On February 26, 1997, respondent issued a notice of
deficiency to petitioner determining deficiencies in and
penalties on petitioner's Federal income taxes as follows:
Penalties
Year Deficiency Sec. 6662(a)
1993 $31,450 $6,290
1994 13,474 2,695
1(...continued)
respondent's motion to dismiss for lack of jurisdiction, arguing
on alternative grounds that petitioner lacks capacity to invoke
this Court's jurisdiction. Since we find for respondent based on
the original motion to dismiss, respondent's alternative argument
raised in the amended motion is moot.
2 All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
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Last modified: May 25, 2011