First National Bank of Wichita Falls v. Commissioner

OPINION.

Black, Judge:

We shall decide the questions in the order previously stated.

The first question is whether we have jurisdiction in the case of the dissolved corporation in Docket No. 111181. This question was raised for the first time in petitioner's opening brief. This Court being a tribunal of limited jurisdiction, a plea of no jurisdiction may be raised at any time. French & Co., 10 B. T. A. 665, 671. See also section 50.07, vol. 9, Mertens Law of Federal Income Taxation. The petition in Docket No. 111181 was filed in the name of “First National Company of Wichita Falls.” The petition…