Legal Opinion

MOORHOUS v. COMMISSIONER OF INTERNAL REVENUE

United States Tax Court

Decided April 23, 2001No. 10761-00LPublishedCited by 67 opinions

On Mar. 16, 1999, R mailed to P-H a final notice of intent to levy concerning P-H's unpaid tax liabilities for the years 1987 through 1992 and 1997. On Apr. 27, 1999, R mailed to P-W a final notice of intent to levy concerning P-W's unpaid tax liabilities for the years 1989 through 1992. On May 10, 1999, Ps filed a joint request for an administrative hearing with the Internal Revenue Service Office of Appeals (Appeals Office). P-H failed to file his request for an…

Read the full summary

On Mar. 16, 1999, R mailed to P-H a final notice of intent to levy concerning P-H's unpaid tax liabilities for the years 1987 through 1992 and 1997. On Apr. 27, 1999, R mailed to P-W a final notice of intent to levy concerning P-W's unpaid tax liabilities for the years 1989 through 1992. On May 10, 1999, Ps filed a joint request for an administrative hearing with the Internal Revenue Service Office of Appeals (Appeals Office). P-H failed to file his request for an administrative hearing within the 30-day period prescribed in sec. 6330, I.R.C. Despite P-H's failure to file a timely request for…

1Opinion of the Court

OPINION

Ruwe, Judge:

This case was assigned to Special Trial Judge Robert N. Armen, Jr., 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 Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

Armen, Special Trial Judge:

This matter is before the Court on respondent’s motion to dismiss for lack of jurisdiction and to strike with respect to Dudley Moorhous and as to taxable years 1987, 1988, and 1997. As explained in detail below, we shall grant respondent’s motion.

Background

On or about…

2Cases cited7 opinions

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. Davis v. CommissionerUnited States Tax Court · 2000
  4. Offiler v. CommissionerUnited States Tax Court · 2000
  5. KENNEDY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001

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

3Cited by67 opinions

  1. Craig v. Comm'rUnited States Tax Court · 2002
  2. Orum v. Comm'rUnited States Tax Court · 2004
  3. Sarrell v. Comm'rUnited States Tax Court · 2001
  4. Downing v. Comm'rUnited States Tax Court · 2002
  5. Weber v. Comm'rUnited States Tax Court · 2004

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API