Jeffrey C. and Kelly O. Stone - Page 2

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               Neither party requested a hearing, and we conclude that none           
          is necessary to decide petitioners' motion.                                 
               Petitioners' motion for summary judgment raises                        
          the following issues:                                                       
               1.   Whether the sharing of tax return information between             
          respondent and the State of Montana violated section 6103(d) or             
          the Privacy Act of 1974, 5 U.S.C. sec. 552a (1994).  We hold that           
          it did not.                                                                 
               2.   Whether the notice of deficiency issued to petitioners            
          is invalid because respondent either (a) did not make notice and            
          demand for tax under section 6303, or (b) did not sign it in pen            
          and ink.  We hold that these circumstances do not invalidate the            
          notice of deficiency.                                                       
               References to Mr. Stone are to petitioner Jeffrey Stone.               
          References to Mrs. Stone are to petitioner Kelly Stone.  Unless             
          otherwise indicated, all section references are to the Internal             
          Revenue Code in effect for the year in issue.  All Rule                     
          references are to the Tax Court Rules of Practice and Procedure.            
                                     Background                                       
          A.   Petitioners                                                            
               Petitioners are married and lived in Belgrade, Montana, when           
          they filed their petition.                                                  









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