- 12 - not alleged that she did not receive the notices of deficiency in sufficient time to timely petition, or that the notices of deficiency are otherwise invalid. See Pietanza v. Commissioner, 92 T.C. 729, 735 (1989), affd. 935 F.2d 1282 (3d Cir. 1991). Accordingly, we shall grant respondent’s motion to dismiss this case for lack of jurisdiction with respect to the taxable years 1993, 1994, 1995, and 1996. To reflect the foregoing, An order will be issued granting respondent’s motion to dismiss for lack of jurisdiction and to strike as to taxable years 1993, 1994, 1995, and 1996.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011