Sandra L. Andary-Stern - Page 4




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               On April 19, 2001, petitioner filed a petition for the 1987            
          through 1994 tax years.3  The Court waived the filing fee.  On              
          May 7, 2001, petitioner filed a motion to dismiss for lack of               
          jurisdiction for the tax years 1987 through 1994.  Petitioner’s             
          motion alleged that the notices of deficiency were not mailed to            
          petitioner’s last known address, and that respondent had reason             
          to know petitioner changed her address because of Forms W-2, Wage           
          and Tax Statement, filed by petitioner’s former employers.  The             
          petition went on to state that petitioner was unable to work                
          after her last job in 1996, until after approximately November              
          2000, when she applied for a position with ETT Gaming.  According           
          to petitioner, she was not hired by ETT Gaming because of the               
          Federal tax lien, and the lien had prevented her from securing              
          employment with other employers.                                            
               The Court directed respondent to respond to petitioner’s               
          motion by June 4, 2001.  On June 4, 2001, respondent filed a                
          motion for extension of time to respond, stating that more time             
          was needed for the investigation.  The Court granted the                    
          extension and ordered respondent to respond by August 4, 2001.              


               2(...continued)                                                        
          liabilities than those prepared by respondent.  For example,                
          respondent’s 1988 return shows a tax of $3,627 while petitioner’s           
          return shows $195.                                                          
               3The petition was with respect to the years 1987-94                    
          inclusive.  Respondent’s assessments are with respect to 1987,              
          1988, 1991, 1992, 1993, and 1994 years.                                     






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