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violation of the automatic stay imposed under 11 U.S.C.
sec. 362(a)(8) (2000). P filed objections to R’s
motions.
Held: The notices of determination underlying the
petitions were issued to petitioner in violation of the
automatic stay imposed under 11 U.S.C. sec. 362(a)(1)
(2000), and, therefore, the Court lacks jurisdiction.
Held, further, R’s motions to dismiss for lack of
jurisdiction shall be denied, and these cases shall be
dismissed for lack of jurisdiction on the Court’s own
motions.
Robert Alan Jones, for petitioner.
Alan J. Tomsic, for respondent.
OPINION
GERBER, Chief Judge: These collection review cases are
before the Court on respondent’s motions to dismiss for lack of
jurisdiction. Respondent contends that the Court lacks
jurisdiction on the ground the petitions for lien or levy action
were filed in violation of the automatic stay imposed under 11
U.S.C. section 362(a)(8) (2000) (the automatic stay).1 As
discussed in detail below, we conclude that we lack jurisdiction
in these cases on the alternative ground that the notices of
determination underlying the petitions were issued to petitioner
1Unless otherwise indicated, section 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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