MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction and petitioner's motion to restrain assessment and collection. As explained in greater detail below, we shall grant respondent's motion and deny petitioner's motion.
Background
Three separate notices of deficiency were issued as follows:
On February 22, 1995, respondent issued...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.
