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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.
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