-5- We also conclude that we lack jurisdiction as to the remaining years. Respondent has not issued to petitioner a notice of deficiency as to any of those years. Nor does there appear to be an alternative basis on which to predicate jurisdiction. On the basis of the record before us and on the analysis above, we conclude that we lack jurisdiction in this case, and we shall grant respondent’s motion. To reflect the foregoing, An appropriate order granting respondent’s motion to dismiss for lack of jurisdiction will be entered.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011