- 4 - Respondent’s counsel appeared and presented argument in support of the pending motion. In particular, counsel introduced into the record copies of petitioner’s above-described income tax returns for 1999 and 2000. Following the hearing, the Court issued an Order stating that it would defer ruling on respondent’s motion to dismiss for 60 days in order to afford the parties an opportunity to try to resolve administratively the substantive issues related to petitioner’s tax liability for the taxable year in issue. The Court also directed that a report be filed by June 24, 2002, advising of the then present status of this matter. On June 24, 2002, respondent filed a Status Report. In the report, respondent stated that a letter had been sent to petitioner requesting information that might have permitted the parties to resolve administratively the substantive issues in this case; respondent also stated that no response had been received from petitioner, nor had the letter been returned to respondent by the Postal Service. Discussion This Court's jurisdiction to redetermine a deficiency depends upon the issuance of a valid notice of deficiency and a timely filed petition. See Rule 13(a), (c); Monge v. Commissioner, 93 T.C. 22, 27 (1989); Normac, Inc. v. Commissioner, 90 T.C. 142, 147 (1988). Section 6212(a) expresslyPage: Previous 1 2 3 4 5 6 7 8 9 Next
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