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On July 27, 2001, respondent filed a motion to extend further the
time to respond to petitioner’s motion. Respondent’s motion
stated that respondent’s records indicated that the last return
filed by petitioner prior to 1996 was for 1985, that petitioner
had several address changes, and that respondent was attempting
to retrieve documents that would show the addresses for
petitioner as of the dates the notices of deficiency were mailed.
The Court granted respondent’s motion and ordered respondent to
respond by September 14, 2001.
On September 6, 2001, respondent sent petitioner a
certificate of release of Federal tax lien, which petitioner
recorded on September 27, 2001.
On September 18, 2001, respondent filed a notice of no
objection to petitioner’s motion to dismiss for lack of
jurisdiction. Respondent’s notice stated that respondent did not
object to petitioner’s motion to dismiss for lack of jurisdiction
with respect to 1987, 1988, 1991, 1992, 1993, and 1994 on the
ground that the notices of deficiency were not mailed to
petitioner’s last known address. Respondent moved to dismiss as
to 1989 and 1990 on the ground that respondent had not made any
determination of a deficiency in petitioner’s income tax for
either of those years. On September 19, 2001, we granted
petitioner’s motion as to 1987, 1988, 1991, 1992, 1993, and 1994
on the ground that the notices of deficiency for those years were
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Last modified: May 25, 2011