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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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Last modified: May 25, 2011