James A. Rochelle - Page 2





                                        - 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 at               






Page:  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