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This matter is before the Court on respondent’s Motion To
Dismiss For Lack Of Jurisdiction, as supplemented. Respondent
contends that this case should be dismissed for lack of
jurisdiction “as the petition requests review of Respondent’s
determination denying relief from liability based upon the
provisions of I.R.C. � 66(c).” As explained in detail below, we
shall grant respondent’s motion, as supplemented.
Background
The record establishes and/or the parties do not dispute the
following:
A. Petitioner and Mr. Sonnabend
At the time that her petition was filed with the Court, and
at all other times relevant to this case, petitioner resided in
Dallas, Texas. As a resident of Texas, petitioner is subject to
the community property laws of that State.
For a period of time, petitioner was married to Henry
Sonnabend (Mr. Sonnabend), a certified public accountant and
senior regional partner with Ernst and Young. Like petitioner,
Mr. Sonnabend was a resident of Texas at all relevant times and
subject to the community property laws of that State.
Prior to the taxable year 1995, petitioner and Mr. Sonnabend
selected as their annual accounting period a fiscal year ending
June 30. Accordingly, petitioner’s taxable year 1995 includes
the period from July 1, 1994 through June 30, 1995.
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Last modified: May 25, 2011