- 2 -
(2000), the Court lacks jurisdiction to review the
disputed determination letters because the Court lacks
jurisdiction over the underlying taxes (frivolous
return penalty under sec. 6702). Ps filed oppositions
to R's motions asserting that the cases should be
dismissed on the ground that the determination letters
are invalid.
Held: R's motions to dismiss will be denied.
Held, further,: These cases will be dismissed on the
ground that the determination letters are invalid.
William B. Meyer and Diane S. Meyer, pro se.
Katrine Shelton and Richard Goldman, for respondent.
OPINION
DAWSON, Judge: These cases were assigned to Chief Special
Trial Judge Peter J. Panuthos pursuant to the provisions of
section 7443A(b)(4).2 The Court agrees with and adopts the
opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: These cases are before
the Court on respondent's Motions to Dismiss for Lack of
Jurisdiction, as supplemented. As discussed in detail below, we
will dismiss these cases for lack of jurisdiction on the ground
that respondent's Notices of Determination Concerning Collection
Action are invalid.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011