Dudley and Dorothy Moorhous - Page 3




                                        - 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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