- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011