- 4 - U.S. 694, 702 (1982); Charlotte’s Office Boutique, Inc. v. Commissioner, 121 T.C. 89, 102 (2003), supplemented by T.C. Memo. 2004-43, affd. 425 F.3d 1203 (9th Cir. 2005); Reagoso v. Commissioner, T.C. Memo. 1993-450, affd. without published opinion 39 F.3d 1171 (3d Cir. 1994). Petitioners also argue that respondent’s motion should be denied because they are time barred from petitioning this Court with respect to the notice of deficiency. We disagree. Because the automatic stay was in effect when the petition was filed, the petition is invalid and must be dismissed for lack of jurisdiction. An order will be issued granting respondent’s motion and directing that this case be dismissed for lack of jurisdiction.Page: Previous 1 2 3 4
Last modified: May 25, 2011