SARKISSIAN v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 27511-11.

T.C. Memo. 2012-278

ARTHUR SARKISSIAN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 1, 2012.


Attorney(s) appearing for the Case

Steven Ray Mather , for petitioner.

Scott B. Burkholder and Kathryn A. Meyer , for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

WHERRY, Judge.

This case is before the Court because of a petition filed on December 1, 2011, in response to a notice of deficiency dated July 29, 2011, determining a deficiency in income tax of $119,307 and a section 6662(a)1 penalty of $23,861.40 for petitioner's 2007 tax year. The case was set for hearing on respondent's and petitioner's competing motions to dismiss for lack of jurisdiction...

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