-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 by
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