-4- 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 byPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011