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February 28, 2002; that DHS determined that Gold Coast had been
overpaid in the amounts of $1,981,400.90 and $330,233.09 for the
years 2001 and 2002, respectively; that Gold Coast did not
transfer money or other property to satisfy the asserted
liabilities; that Gold Coast disputed the asserted liabilities;
that Gold Coast filed amended income tax returns claiming a
return and allowance for the disputed liabilities asserted by
DHS; that petitioners filed amended income tax returns for 2001
and 2002 reporting Mr. Wadsworth’s share of the resulting Gold
Coast loss; that DHS’s original finding of overpayment was
reversed by an administrative law judge in 2004; that Gold Coast
is not entitled to claim as a deduction for 2001 and 2002 the
disputed liabilities asserted by DHS; and that petitioners must
therefore recognize Mr. Wadsworth’s distributive share of Gold
Coast income for 2001 and 2002.
After receiving an extension of time to file, petitioners
timely filed their reply on November 21, 2005. Petitioners filed
with their reply a motion to dismiss for lack of jurisdiction and
a motion to strike paragraph 8 from respondent’s answer.
Petitioners filed an amended motion to dismiss for lack of
jurisdiction (amended motion to dismiss) and an amended motion to
strike paragraph 8 from respondent’s answer (amended motion to
strike) on December 14, 2005. The amended motions contained
substantially the same arguments as the original motions.
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