- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011