Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders - Page 6

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          filed amended objections.  In these documents, petitioner contends          
          that his petition was timely filed:                                         
                    as to all Notices of Deficiency allegedly                         
                    issued by IRS [Internal Revenue Service] in                       
                    October, 1996 including F1040 1992, 1993 and                      
                    Section 4975 because of the language Petitioner                   
                    uses in said Petition and because the                             
                    Respondent had sufficient Notice that                             
                    Petitioner was contesting  all  Notices  of                       
                    Deficiency whether or not said Notices were                       
                    attached to the Petition.                                         
          In addition, petitioner asserts that respondent's motion to dismiss         
          should be denied on the ground that the second and third deficiency         
          notices were not sent to petitioner's last known address.  In this          
          regard, petitioner maintains that he was informed of the second and         
          third deficiency notices only when he received (on August 1, 1997)          
          respondent's motion to dismiss.                                             
               On September 22, 1997, the Court held a hearing on respondent's        
          motion to dismiss.                                                          
               On October 20, 1997, petitioner filed a "Motion to Dismiss--           
          (F1040 1992 Income Taxes) (Section 4975 Excise Taxes Pre 1993)".            
          In this motion, petitioner contends that the mailing address used           
          by respondent to contact him should not have been the Hickory Hills         
          address with respect to the second and third deficiency notices.            
          Consequently, petitioner continues, the second and third deficiency         
          notices were improperly mailed and the period of limitations for            
          making a deficiency assessment expired with respect to his and his          
          wife's 1992 income tax liability as well as his liability for               





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