Duane E. Hudspath - Page 4

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          and 1997 notice).  That notice made certain determinations                  
          relating to the adjustments resulting from the IRS’s respective             
          examinations of SCC and WIN (TEFRA determinations), as well as              
          certain other unrelated determinations (non-TEFRA determina-                
          tions).  In response to the 1996 and 1997 notice, on July 14,               
          2000, Mr. Hudspath filed a petition with the Court, thereby                 
          commencing Hudspath v. Commissioner, docket No. 7901-00 (peti-              
          tioner’s non-TEFRA case at docket No. 7901-00).                             
               In response to the respective SCC-FPAA and WIN-FPAA, on July           
          17, 2000, Jimmy C. Chisum (Mr. Chisum) filed a petition with the            
          Court purportedly on behalf of SCC and WIN, thereby commencing              
          Stephens City Chiropractic, PLC v. Commissioner, docket No. 7982-           
          00 (TEFRA case at docket No. 7982-00 or partnership-level pro-              
          ceeding).  On April 2, 2001, the Tax Court granted the motion of            
          the Commissioner to dismiss the TEFRA case at docket No. 7982-00            
          for lack of jurisdiction because Mr. Chisum, the purported                  
          trustee and the purported tax matters partner of SCC and of WIN,            
          failed to establish his authority to act on behalf of those                 
          respective entities.                                                        
               On December 7, 2001, the Court granted the Commissioner’s              
          motion to dismiss for lack of jurisdiction and to strike peti-              
          tioner’s non-TEFRA case at docket No. 7901-00 insofar as it                 
          pertained to the TEFRA determinations in the 1996 and 1997 notice           
          (respondent’s motion).  That was because such notice insofar as             
          it pertained to such determinations was invalid and prohibited by           




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