Zimmerman v. Commissioner
United States Tax Court
Ps filed a bankruptcy petition on Sept. 3, 1991. On May 20, 1992, R issued a notice of deficiency to Ps determining deficiencies for the taxable years 1984 and 1985. On June 5, 1992, the bankruptcy court issued an order discharging Ps.
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Ps filed a bankruptcy petition on Sept. 3, 1991. On May 20, 1992, R issued a notice of deficiency to Ps determining deficiencies for the taxable years 1984 and 1985. On June 5, 1992, the bankruptcy court issued an order discharging Ps. The discharge order reflected that copies were mailed to all creditors and interested parties on Oct. 20, 1992. On Sept. 10, 1992, R issued a notice of deficiency to Ps for the taxable year 1986. A petition was filed on Dec. 11, 1992, seeking a redetermination with respect to the taxable years 1984, 1985, and 1986. R filed a motion to dismiss for lack of…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Chief Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge:
This matter is before the Court on respondent’s motion to dismiss for lack of jurisdiction. Respondent asserts that we lack jurisdiction in this case on the ground that the petition, to the extent that it pertains to the taxable years 1984 and 1985, was…
2Cases cited8 opinions
- Monge v. CommissionerUnited States Tax Court · 1989
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- McCormick v. CommissionerUnited States Tax Court · 1970
- Neilson v. CommissionerUnited States Tax Court · 1990
- Smith v. CommissionerUnited States Tax Court · 1991
3 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Kieu v. CommissionerUnited States Tax Court · 1995
- In Re HakimUnited States Bankruptcy Court, N.D. California · 1999
- Chan Q. Kieu and Quynh Kieu v. CommissionerUnited States Tax Court · 1995
- Clevenger v. CommissionerUnited States Tax Court · 1998
- James A. Rochelle v. CommissionerUnited States Tax Court · 2001
6 more not listed; retrieve them via the Exa API.