Investment Research Associates, Inc. - Page 3

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          for lack of jurisdiction.                                                   
                                     Background                                       
               In Inv. Research Associates, Ltd. v. Commissioner, T.C.                
          Memo. 1999-407, a Memorandum Opinion filed in 28 consolidated               
          dockets, the Court held, inter alia, that Investment Research               
          Associates, Inc. (petitioner) was liable for deficiencies,                  
          additions to tax, and an accuracy-related penalty for the years             
          1980 and 1982 to 1989.2  The Court entered decisions in                     
          petitioner’s deficiency cases in September 2001.  Petitioner did            
          not appeal the Court’s decisions in its deficiency cases and                
          those decisions are now final.  Secs. 7481(a)(1), 7483.3  In                
          February 2002, respondent assessed the deficiencies, additions to           
          tax, and accuracy-related penalty described above, as well as               
          interest.                                                                   
               On October 28, 2002, respondent mailed to petitioner a                 
          Notice of Federal Tax Lien Filing and Your Right to a Hearing               
          Under IRC 6320 with regard to petitioner’s unpaid taxes for 1980,           
          1982, 1984, 1985, 1986, 1987, 1988, 1989, and 1997 (hereinafter             


               2  Investment Research Associates, Inc., filed petitions for           
          redetermination with the Court at docket Nos. 43966-85, 45273-86,           
          30830-88, 27444-89, 25875-90, 23178-91, 19314-92, and 25976-93.             
               3  In accordance with the Supreme Court’s decision in                  
          Ballard v. Commissioner, 544 U.S. 40,   , 125 S. Ct. 1270, 1285             
          (2005), the Court’s Memorandum Opinion in Inv. Research                     
          Associates, Ltd. v. Commissioner, T.C. Memo. 1999-407, recently             
          was deemed stricken with regard to taxpayers other than                     
          petitioner.                                                                 





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