Legal Opinion

Gati v. Commissioner

United States Tax Court

Decided August 11, 1999No. 3730-99PublishedCited by 27 opinions

On Aug. 13, 1998, R mailed a final determination letter to Ps denying their request for abatement of interest for the taxable year 1978. On Feb. 17, 1999, Ps filed an imperfect petition for review with the Court under sec. 6404(g), I.R.C. HELD: This case will be dismissed for lack of jurisdiction on the ground that the petition was not filed with the Court within the 180-day period prescribed in sec. 6404(g)(1), I.R.C.

1Opinion of the Court

OPINION

Dawson, Judge:

This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to Rules 180, 181, and 183. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

The Court agrees with and adopts the opinion of the 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. The question presented is whether the…

2Cases cited7 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. Frieling v. CommissionerUnited States Tax Court · 1983
  3. William L. King and Darlene E. King v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
  4. King v. CommissionerUnited States Tax Court · 1987
  5. Bourekis v. Comm'rUnited States Tax Court · 1998

2 more not listed; retrieve them via the Exa API.

3Cited by27 opinions

  1. Fernandez v. CommissionerUnited States Tax Court · 2000
  2. Lunsford v. Comm'rUnited States Tax Court · 2001
  3. Ewing v. CommissionerUnited States Tax Court · 2002
  4. Block v. Comm'rUnited States Tax Court · 2003
  5. Meyer v. Comm'rUnited States Tax Court · 2000

22 more not listed; retrieve them via the Exa API.

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