Efco Tool Co. v. Commissioner
United States Tax Court
Respondent on Mar. 9, 1982, simultaneously issued to petitioner a statutory notice of deficiency and a final revocation letter as to the qualified status of petitioner's profit-sharing plan. On Apr. 30, 1982, respondent issued to petitioner a final revocation letter as to petitioner's retirement pension plan. On June 15, 1982, petitioner filed one petition which was docketed as a request for redetermination, not as a declaratory judgment action.
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Respondent on Mar. 9, 1982, simultaneously issued to petitioner a statutory notice of deficiency and a final revocation letter as to the qualified status of petitioner's profit-sharing plan. On Apr. 30, 1982, respondent issued to petitioner a final revocation letter as to petitioner's retirement pension plan. On June 15, 1982, petitioner filed one petition which was docketed as a request for redetermination, not as a declaratory judgment action. Petitioner's attorney conceded that this Court lacks jurisdiction over the matter as to the statutory notice of deficiency and the first final…
1Opinion of the Court
OPINION
Dawson, Chief Judge:
This case was assigned pursuant to section 7456(c) and (d), Internal Revenue Code of 1954, as amended, and Delegation Order No. 8 of this Court, 81 T.C. VII (July 1983), to Special Trial Judge Francis J. Cantrel for the purpose of conducting the hearing and ruling on respondent’s motion to dismiss for lack of jurisdiction. After a review of the record, we agree with, and adopt, his opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Cantrel, Special Trial Judge:
Petitioner brought an action, docketed as a deficiency case under section 6213(a),1…
2Cases cited11 opinions
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- Thompson v. CommissionerUnited States Tax Court · 1978
- Gladstone Foundation v. CommissionerUnited States Tax Court · 1981
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