Stephen C. Loadholt Trust, Debra M. Lance Trustee, et al. - Page 2




                                         - 2 -                                          
               Debra M. Lance (trustee), for petitioner in docket No.                   
          18158-99L.                                                                    
               Samuel Lance, Jr. (trustee), for petitioner in docket No.                
          18159-99L.                                                                    
               Debra M. Lance (trustee), for petitioner in docket No.                   
          18521-99L.                                                                    
               J. Craig Young, for respondent.                                          


                                  MEMORANDUM OPINION                                    

               THORNTON, Judge:  These cases are before the Court on                    
          respondent’s motions to dismiss for lack of jurisdiction.2  As                
          discussed below, we shall grant respondent’s motions.                         
               Unless otherwise indicated, section references are to the                
          Internal Revenue Code as amended.                                             
                                      Background                                        
               In these consolidated cases, trustees (the trustees) of                  
          three purported trusts (the trusts) petitioned this Court for                 
          redeterminations under section 6330(d).  On their Forms 1041,                 
          U.S. Income Tax Return for Estates and Trusts, for taxable year               
          1997, each of the trusts reported income tax liability of zero                
          and certain amounts of income tax withholding credits, thereby                



               2 The instant cases involve the same jurisdictional issue as             
          Boone Trust v. Commissioner, T.C. Memo. 2000-350, also decided                
          today.                                                                        





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