Erma Schrader v. Commissioner of Internal Revenue

Appellant, Erma Schrader appeals the Tax Court’s dismissal of her petition for review of a deficiency in her 1983 federal income tax. Because we find dismissal of one year of a multi-year petition is not a final appealable order, we dismiss this appeal for lack of jurisdiction.

I

Appellee, the Commissioner of Internal Revenue, determined a deficiency in appellant’s federal income tax for three years: 1983, 1984 and 1985. On March 8, 1988, the taxpayer filed a pro se petition for redetermination in the Tax Court objecting to any income tax deficiencies for all three years. The Commissioner moved…