- 2 - taxable years beginning only after Aug. 7, 1997, and are therefore not applicable to the years before the Court. Held further, R's motion to dismiss for lack of jurisdiction and to strike will be granted. David D. Aughtry, for petitioner. Ronald Buch and William L. Blagg, for respondent. MEMORANDUM OPINION COHEN, Chief Judge: This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE ARMEN: Special Trial Judge: This matter is before the Court on respondent's Motion To Dismiss For Lack Of Jurisdiction And To Strike With Respect To Penalties/Additions To Tax. Respondent moves to dismiss for lack of jurisdiction and to strike allegations in the petition pertaining to the accuracy- related penalty under section 6662. As explained in detail below, we shall grant respondent's motion. 1 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011