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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 through
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