Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders - Page 9

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          lack of jurisdiction petitioner's request for a redetermination of          
          the 1992 and 1993 income tax deficiencies as well as the 1992-95            
          section 4975 excise tax deficiencies.                                       
          Discussion                                                                  
               The jurisdiction of this Court to redetermine a deficiency             
          depends upon the issuance of a valid notice of deficiency and a             
          timely filed petition.  Rule 13(a) and (c); Levitt v. Commissioner,         
          97 T.C. 437, 441 (1991); Monge v. Commissioner, 93 T.C. 22, 27              
          (1989); Normac, Inc. v. Commissioner, 90 T.C. 142, 147 (1988).  In          
          essence, petitioner contends that the second and third deficiency           
          notices were not valid because they were issued beyond the                  
          limitations period, and respondent contends that we do not have             
          jurisdiction to consider the second and third deficiency notices            
          because there was no indication that respondent's determinations set        
          forth therein were being contested in a timely filed petition (i.e.,        
          the January 2, 1997, petition).                                             
               We shall first consider respondent's motion to dismiss for lack        
          of jurisdiction.  The Rules of this Court provide that                      
                    Ordinarily, a separate petition shall be filed                    
                    with respect to each notice of deficiency or                      
                    each notice of liability.  However, a single                      
                    petition may be filed seeking a redetermination                   
                    with respect to all notices of deficiency or                      
                    liability directed to one person alone or to                      
                    such person and one or more other persons or to                   
                    a husband and a wife individually, except that                    
                    the Court may require a severance and a                           
                    separate case to be maintained with respect to                    
                    one or more of such notices.  Where the notice                    
                    of deficiency or liability is directed to more                    




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