- 2 - deficiency, we shall grant R’s motion to dismiss and strike so much of the petition as seeks review of the denial of the request for relief made pursuant to sec. 66(c), I.R.C. Kathryn Bernal, pro se. David Jojola, for respondent. OPINION DAWSON, Judge: This case was assigned to Chief Special Trial Judge Peter J. Panuthos, 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 Chief Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PANUTHOS, Chief Special Trial Judge: This matter is before the Court on respondent’s motion to dismiss for lack of jurisdiction and to strike as to the taxable years 1993, 1994, 1995, and 1996. As explained in detail below, we shall grant respondent’s motion to dismiss.2 1 Section references are to the Internal Revenue Code, and Rule references are to the Tax Court Rules of Practice and Procedure. 2 The petition places in dispute the taxable year 1992 as well as the taxable years 1993 through 1996. Respondent does not seek dismissal with respect to 1992. Thus, the order will strike references to all tax years other than 1992. As the record is incomplete, we do not address jurisdictional issues with respect to 1992 in this opinion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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