- 2 - Lawrence R. Jones, Jr., for petitioner. Denise G. Dengler, for respondent. OPINION VASQUEZ, Judge: Respondent determined the following deficiencies in Federal income tax and section 6662(a) accuracy- related penalties: Penalty Year Deficiency Sec. 6662(a) 1995 $229,096 $45,819 1996 34,549 6,910 This case is before the Court on the parties’ cross-motions to dismiss for lack of jurisdiction. Petitioner has moved for dismissal in his favor on the ground that respondent’s notice of deficiency is invalid. Respondent moves for dismissal in his favor on the ground that the petition in this case was not timely filed. A hearing was held with respect to these motions on February 5, 2001. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background Petitioner resided in Austin, Texas at the time the petition in this case was filed. Petitioner is an attorney who performed legal services in the Dallas, Texas, area during the years atPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011