Kellogg v. Commissioner
United States Tax Court
P, a beneficiary of estate, filed a petition seeking a redetermination of transferee liability. Attached to the petition was a letter signed by a revenue officer demanding payment from P of delinquent taxes assessed against estate. Held, no notice of deficiency or notice of transferee liability was issued. R's motion to dismiss for lack of jurisdiction granted. Rule 13, Tax Court Rules of Practice and Procedure; secs. 6212, 6213, 6901, I.R.C. 1954, as amended.
1Opinion of the Court
OPINION
FEATHERSTON, Judge:
Respondent’s motion to dismiss for lack of jurisdiction filed herein was assigned to Special Trial Judge Francis J. Cantrel pursuant to section 7456(d)(4) (redesignated section 7443A(b)(4) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 1755) and Rule 180. 1 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:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction filed on May 27, 1986. Respondent seeks…
2Cases cited22 opinions
- Jarvis v. CommissionerUnited States Tax Court · 1982
- Foster v. Comm'rUnited States Tax Court · 1983
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Scar v. CommissionerUnited States Tax Court · 1983
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