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West, Tierra Verde, Florida, 33715. This motion to withdraw was
also granted.
On August 4, 1998, IRS issued a notice of deficiency (1998
notice of deficiency) to petitioner for its May 31, 1993, and
1994 tax years. IRS sent copies of the notice to Starvest at its
Florida address, to Jacques de Bruijn, to Alan Swartz, and to
Mario Boon at his address in The Netherlands.
Jacques de Bruijn retained the law firm of Finkelstein and
Associates (Finkelstein) to represent Starvest in regard to the
1997 notice of deficiency and the 1998 notice of deficiency.
Finkelstein filed a petition in the name of Starvest with this
Court on November 2, 1998, requesting a redetermination of the
1998 notice of deficiency. That case is docket No. 17705-98.
On December 22, 1998, respondent filed a motion to dismiss
docket No. 17705-98 for lack of jurisdiction on the same grounds
as the motion to dismiss docket No. 16948-97; i.e., lack of
capacity and authorization.
On January 19, 1999, another petition was filed in
Starvest's name for the redetermination of the taxes determined
in the 1998 notice of deficiency. This petition was submitted by
Mario Boon pursuant to the 1998 notice of deficiency he received
at his address in The Netherlands. That petition was filed as
docket No. 1372-99. Boon mailed the petition from his address in
The Netherlands.
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