- 2 - Janet N. Moore, pro se. John R. Mikalchus and Kerry Bryan, for respondent. OPINION COHEN, Chief Judge: This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183. Unless otherwise indicated, section references are to sections of the Internal Revenue Code as amended, and Rule references to the Tax Court Rules of Practice and Procedure. 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: This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. As discussed in detail below, we shall grant respondent's motion. Background Janet N. Moore (petitioner) was an officer of Atlas Elevator Company (Atlas). Atlas failed to pay over to the Government what respondent refers to as Federal trust fund taxes (Federal Insurance Contributions Act taxes under sections 3101 et seq., and employee income tax withholding under sections 3401 throughPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011