T.C. Memo. 1999-88 UNITED STATES TAX COURT THOMAS GERALD ROOTS AND LINDA VESTA ROOTS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14438-98. Filed March 23, 1999. Petitioners move to dismiss for lack of jurisdiction on the grounds that (1) the primary adjustment in the notice of deficiency is wrong and (2) the period of limitations on assessment expired before the notice of deficiency was issued. 1. Held: Neither of these matters goes to the jurisdiction of this Court, and so petitioners' motion to dismiss is denied. 2. Held, further, treating petitioners' motion as a motion for summary judgment on the limitations question, there is a genuine issue of material fact (a dispute about whether petitioners' purported signatures on a Form 872 are genuine), and so petitioners are not entitled to summary judgment.Page: 1 2 3 4 5 6 7 Next
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