Gene Autry Glenn, II - Page 3

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               This case is before the Court on respondent’s motion to                
          dismiss for lack of jurisdiction.  For the reasons stated below,            
          we must grant respondent’s motion.                                          
                                     Background                                       
               On July 5, 2006, petitioner filed a petition with this Court           
          for relief pursuant to section 6015 with regard to the taxable              
          year 2003.  Attached to the petition is a letter from the                   
          Internal Revenue Service to petitioner dated November 25, 2005,             
          informing petitioner that a “preliminary determination” had been            
          made regarding his request for relief pursuant to section 6015.             
               On November 30, 2006, respondent filed a motion to dismiss             
          for lack of jurisdiction (motion to dismiss), on the ground that            
          the petition was not filed within the time prescribed by section            
          6015(e)(1)(A).  Attached to respondent’s motion is a computerized           
          version of the Final Notice of Determination (final notice) sent            
          to petitioner denying petitioner’s request for section 6015                 
          relief.  The final notice is dated January 17, 2006.                        
                                     Discussion                                       
               The jurisdiction of this Court depends on the timely filing            
          of a petition.  Rule 13(c).  Section 6015(e)(1)(A) requires that            
          a petition to determine relief from joint and several liability             
          must be filed no later than the close of the 90th day after “the            
          date the Secretary mails, by certified or registered mail to the            







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