- 4 - the petition was filed by petitioner, who is also a notice partner, within the 60-day period prescribed in section 6226(b)(1). See Barbados #6 Ltd. v. Commissioner, 85 T.C. 900, 904 (1985). (Consistent with this concession, we shall deny respondent's Motion to Dismiss for Lack of Jurisdiction insofar as the taxable year 1993 is concerned.) On November 5, 1997, the Court issued an order calendaring respondent's motion to dismiss for hearing on December 3, 1997. The order included a reminder to the parties of the applicability of Rule 50(c). On November 19, 1997, petitioner filed a motion to continue the hearing. On November 21, 1997, the Court granted petitioner's motion and continued the hearing of this matter to December 17, 1997. The Court again reminded the parties of the applicability of Rule 50(c). On December 5, 1997, petitioner filed a second motion to continue the hearing. Petitioner's motion was denied on December 10, 1997. This matter was called for hearing at the Court's motions session in Washington, D.C., on December 17, 1997. Counsel for respondent appeared at the hearing and presented argument in support of respondent's motion to dismiss the taxable year 1992. No appearance was made by or on behalf of petitioner, nor did petitioner file a statement with the Court pursuant to Rule 50(c).Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011