- 3 -
and adopts the Opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s Motion To Dismiss For Lack Of Jurisdiction And To
Strike With Respect To Dudley Moorhous And As To Taxable Years
1987, 1988, and 1997. As explained in detail below, we shall
grant respondent’s motion.
Background
On or about March 16, 1999, respondent mailed to petitioner
Dudley Moorhous a Final Notice Of Intent To Levy And Notice Of
Your Right To A Hearing (notice of intent to levy) concerning his
unpaid tax liabilities for the years 1987 through 1992 and 1997.2
Petitioner Dudley Moorhous received the notice of intent to levy
on March 18, 1999, as reflected on the U.S. Postal Service Form
3811, Domestic Return Receipt, that was executed upon delivery of
the notice. On or about April 27, 1999, respondent mailed to
petitioner Dorothy Moorhous a notice of intent to levy concerning
1(...continued)
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
2 The notice of intent to levy stated that petitioner
Dudley Moorhous owed amounts from prior notices, additional
penalties, and interest totaling $24,944.87, $21,014.05,
$17,849.47, $10,228.66, $9,947.46, $19,333.82, and $101.23 for
the years 1987, 1988, 1989, 1990, 1991, 1992, and 1997,
respectively.
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