Brandon Christopher Merriweather - Page 7




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          those years.3                                                               
               In view of the foregoing, we hold that respondent may                  
          proceed with collection with respect to petitioner’s tax                    
          liabilities for 1995 and 1996.  Accordingly, we shall grant                 
          respondent’s Motion To Dismiss The Tax Years 1995 And 1996 For              
          Failure To State A Claim Upon Which Relief Can Be Granted.                  
          Thereafter, the current proceedings will go forward with respect            
          to petitioner’s claims for the taxable year 1997.                           
               In order to give effect to the foregoing,                              


                                             An appropriate order granting            
                                        respondent’s motion will be issued.           
















          3  The decision to be entered in this case at the conclusion                
          of all of the proceedings will indicate that we sustain                     
          respondent's administrative determination to proceed with                   
          collection against petitioner for the taxable years 1995 and                
          1996.  However, such decision is not intended to serve as a                 
          review of respondent's determinations as to petitioner's                    
          underlying tax liabilities for 1995 and 1996.                               





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