- 3 - 2002, trial date. By order dated March 11, 2002, the Court granted petitioner’s motion for a continuance, retained jurisdiction, and ordered the parties to file a status report on or before May 10, 2002. On May 10, 2002, respondent filed a status report with the Court, expressing a concern that the Court may lack jurisdiction in this case. Respondent’s status report stated that the National Office of the Internal Revenue Service was reviewing the matter and that respondent subsequently expected to file a motion to dismiss for lack of jurisdiction. On May 16, 2002, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the notice of deficiency is invalid because respondent did not determine a “deficiency” within the meaning of sections 6211 and 6665. On May 21, 2002, the Court ordered petitioner to file an objection, if any, to respondent’s motion to dismiss on or before June 21, 2002. On June 19, 2002, petitioner filed an objection to respondent’s motion to dismiss. On September 9, 2002, pursuant to an order of the Court, respondent’s motion was called for hearing at the Court’s trial session in New York, New York. Upon the basis of the record, we summarize the facts as follows. Sometime in January 1997, petitioner filed her 1993 Form 1040, U.S. Individual Income Tax Return. Petitioner reported no income tax liability on the 1993 tax return.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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