- 7 - H. Respondent’s Motion To Dismiss As stated, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Respondent contends that the Court lacks jurisdiction on the grounds that: (1) The petition was not timely filed with regard to the notice of deficiency dated February 9, 2000; and (2) respondent did not issue to petitioner a notice of determination concerning collection actions under sections 6320 or 6330. Petitioner filed a notice of objection to respondent’s motion. Pursuant to notice, this matter was called for hearing at the Court’s motions session in Washington, D.C. Counsel for respondent appeared at the hearing and offered argument in support of respondent’s motion to dismiss. Although there was no appearance by or on behalf of petitioner at the hearing, petitioner filed with the Court a written statement pursuant to Rule 50(c). After the hearing, the Court issued Orders directing respondent to file supplements to his motion to dismiss. Respondent complied with the Court’s Orders. Discussion The Tax Court is a court of limited jurisdiction. We may exercise jurisdiction only to the extent expressly authorized by statute. Breman v. Commissioner, 66 T.C. 61, 66 (1976).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011