- 4 - 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.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