2
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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