T.C. Memo. 1999-67
UNITED STATES TAX COURT
UNILEVER SUPERANNUATION TRUSTEES LIMITED, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10022-97. Filed March 5, 1999.
K. Peter Schmidt, for petitioner.
Gary D. Kallevang, for respondent.
MEMORANDUM OPINION
LARO, Judge: Petitioner moves for summary judgment,
asserting that section 6501 does not allow respondent to assess
tax for the years in issue. Respondent moves for partial summary
judgment, asserting primarily that the notices of deficiency are
timely under section 6501(c)(3). Respondent issued the notices
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