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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 (1) Petitioner's Motion to Restrain Assessment or Collection;
and (2) Respondent's Motion to Dismiss for Lack of Jurisdiction.
Background
On August 26, 1991, respondent sent petitioner a notice of
deficiency for the taxable year 1988 (the notice of deficiency
for 1988). In the notice of deficiency for 1988, respondent
determined the following deficiency in petitioner's Federal
income tax and additions to tax:
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6653(a)(1)
1988 $9,713 $320 $486
On February 23, 1993, respondent sent petitioner a notice of
deficiency for the taxable year 1989 (the notice of deficiency
for 1989). In the notice of deficiency for 1989, respondent
determined the following deficiency in petitioner's Federal
income tax and additions to tax:
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654
1989 $27,822 $4,291.75 $1,080.24
1 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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