Sandra L. Andary-Stern - Page 5




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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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