Hanna & Associates, P.C. - Page 5

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          respondent should be precluded from issuing a deficiency notice             
          to a dissolved corporation.  As we observed in Great Falls                  
          Bonding Agency, Inc. v. Commissioner, supra at 306:                         
               At first blush, it does seem anomalous that                            
               respondent would issue a statutory notice of deficiency                
               to a taxpayer and then turn around and say that there                  
               is no taxpayer who can petition this Court for a                       
               redetermination of the determined deficiency--as * * *                 
               [respondent] has done here. Yet, section 6212(b)(1) is                 
               explicit in its language which permits respondent, in                  
               the absence of a notice of fiduciary relationship, to                  
               send a notice of deficiency to a corporation which has                 
               terminated its existence--as has the petitioner.                       
                                                                                     
          There being no indication that petitioner provided                          
          respondent with a notice of a fiduciary relationship under                  
          sections 6903 and 6212(b)(1), respondent was justified in issuing           
          the disputed deficiency notice directly to petitioner                       
          notwithstanding its dissolution.                                            
          Accordingly, we grant respondent's motion to dismiss for                    
          lack of jurisdiction on the ground that petitioner lacked                   
          capacity under Rule 60(c) to invoke this Court's jurisdiction.              
          To reflect the foregoing,                                                   


          An appropriate order                                                        
          of dismissal for lack                                                       
                                                  of jurisdiction will                
                                                  be entered.                         








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