- 2 -
Held: The certified mail list is a record of
regularly conducted activity under Fed. R. Evid. 802(6)
and is self-authenticated by the accompanying
declarations under Fed. R. Evid. 902(11).
Stanley D. Clough and Rosemary A. Clough, pro se.
Karen N. Sommers, Melinda G. Williams, and Donna F. Herbert,
for respondent.
OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to the provisions of section
7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with
and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge: This matter is before the
Court on respondent’s motion to dismiss for lack of jurisdiction,
as supplemented. Respondent contends that the Court lacks
jurisdiction in this case on the ground that the petition was not
filed within the time prescribed in sections 6213(a) and 7502(a).
Petitioners resided in Sylmar, California, at the time the
petition was filed.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code, as amended, and Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011