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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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