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Held, further: P’s motion to strike will be
granted in that the restrictive language in R’s notice
is deemed stricken, and M’s notice of intervention will
be filed.
Jack Barry Schiffman, for petitioner.
Emly B. Berndt, for respondent.
OPINION
DAWSON, Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos, pursuant to the provisions of
section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court
agrees with and adopts the opinion of the Chief Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on petitioner’s motion to strike. As explained in
detail below, we shall grant petitioner’s motion.
Background
Petitioner filed joint Federal income tax returns with her
then husband, Stanley David Murray (Mr. Murray), for the taxable
years 1992 to 1996.
1Section references are to sections of the Internal Revenue
Code, as amended, and Rule references are to the Tax Court Rules
of Practice and Procedure.
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