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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
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