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dispute the determination for 1994 they had 30 days to "file a
complaint in the appropriate United States District Court".
Petitioners were issued a separate notice of determination for
tax years 1995 through 1997. The notice of determination for
those years advised them that if they wanted to dispute the
determination, "you must file a petition with the United States
Tax Court within 30 days from the date of this letter."
Petitioners filed with the Court a petition and an amended
petition for redetermination of proposed collection action with
respect to both the notice for 1994 as well as the one for 1995
through 1997.
Respondent contends in the motion to dismiss that the
Court's jurisdiction to review administrative determinations
respecting collection matters is limited to cases where the
underlying tax liability is of a kind within the Court's normal
deficiency jurisdiction. Respondent asserts that the Court lacks
jurisdiction over the FICA taxes at issue in this case, and
therefore the Court lacks jurisdiction to review respondent's
administrative determination to proceed with collection against
petitioners. Petitioners filed papers in opposition to
respondent's motion to dismiss.
This matter was called for hearing at the Court's trial
session in Hartford, Connecticut. Counsel for respondent
appeared at the hearing and argued in support of the motion to
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Last modified: May 25, 2011