John C. Hom & Associates, Inc. v. Commissioner
United States Tax Court
R moved to dismiss the proceeding for lack of jurisdiction because petitioner's corporate powers were suspended at the time the petition was filed. Petitioner contends that the notice of deficiency is invalid for failing to include the address and telephone number of the local office of the National Taxpayer Advocate and that inclusion of a Web page link is inadequate compliance with I.R.C. sec. 6212. Held: The notice was not invalid. The motion to dismiss will be granted.
1Opinion of the Court
OPINION
Cohen, Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction. The issues for decision are whether the notice of deficiency was invalid for failing to include the address and telephone number of the local office of the National Taxpayer Advocate, as directed by section 6212(a), and whether the case should be dismissed for lack of jurisdiction because petitioner’s corporate status was suspended at the time the petition was filed. All section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice…
2Cases cited23 opinions
- United States v. James Daniel Good Real PropertySupreme Court of the United States · 1993
- Brock v. Pierce CountySupreme Court of the United States · 1986
- Monge v. CommissionerUnited States Tax Court · 1989
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Frieling v. CommissionerUnited States Tax Court · 1983
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3Cited by6 opinions
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- John C. Hom & Associates, Inc. v. CommissionerUnited States Tax Court · 2013
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