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ODEND'HAL v. COMMISSIONER

Docket Nos. 6724-89, 6725-89.

95 T.C. 617 (1990)

FORTUNE J. ODEND'HAL, JR. IV AND CAROLYN L. ODEND'HAL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT FORTUNE J. ODEND'HAL, JR. IV, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 10, 1990.

Attorney(s) appearing for the Case

D. Alden Newland, for the petitioners.

Dianne I. Crosby, for the respondent.

OPINION

NIMS, Chief Judge:

This case is before the Court on respondent's motions to dismiss for lack of jurisdiction as to section 6621(c). (Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. Section 7721(b) of the Omnibus Budget Reconciliation Act of 1989, Pub. L. 101-239, 103 Stat. 2106, 2399, repealed section 6621(c) effective for returns the due date of which (determined without...

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