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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
ARMEN, Special Trial Judge: This case is before the Court
on respondent's Motion to Dismiss for Lack of Jurisdiction on the
ground that the petition was not filed within the time prescribed
by section 6213(a) or section 7502.
Background
On June 11, 1993, respondent sent petitioner duplicate
original notices of deficiency for the taxable years 1985, 1986,
1987, and 1989 (the first notices of deficiency). In the first
notices of deficiency, respondent determined the following
deficiencies in petitioner's Federal income taxes and additions
to tax:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 16653(a)(1) 26653(a)(2) 6654
1985 $9,930 $2,483 $497 applicable $569
1986 10,714 2,679 536 applicable 519
1987 8,159 2,040 408 applicable 439
1989 53,364 13,341 --- --- 3,609
1 For 1986 and 1987, sec. 6653(a)(1)(A).
2 For 1986 and 1987, sec. 6653(a)(1)(B).
Also on June 11, 1993, respondent sent petitioner and his
wife Bertha Millsap duplicate original notices of deficiency for
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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