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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).
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