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OPINION
DAWSON, Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos pursuant to Rules 180, 181, and
183. 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.
The Court agrees with and adopts the opinion of the Special
Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's Motion to Dismiss for Lack of
Jurisdiction. The question presented is whether the petition was
filed within the 180-day period prescribed in section 6404(g)(1).
(Section 6404(g) was redesignated section 6404(i) under the
Internal Revenue Service Restructuring and Reform Act of 1998,
Pub. L. 105-206, secs. 3305(a) and 3309(a), 112 Stat. 743, 745,
effective with respect to tax years beginning after December 31,
1997.)
Background
On August 13, 1998, respondent mailed a final determination
letter to petitioners denying their request for an abatement of
interest for the taxable year 1978. The final determination
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