Starvest U.S., Inc. - Page 1
















                                 T.C. Memo. 1999-314                                  


                               UNITED STATES TAX COURT                                


                         STARVEST U.S., INC., Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos.  16948-97, 17705-98,   Filed September 23, 1999.           
                         1372-99.                                                     

               David Finkelstein, for petitioner.                                     
               William R. McCants, for respondent.                                    


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               COUVILLION, Special Trial Judge:  These consolidated cases             
          are before the Court on the parties' motions to dismiss for lack            
          of jurisdiction.  In docket No. 16948-97, petitioner moves to               
          dismiss on the ground that the notice of deficiency is invalid              
          because it was not mailed to petitioner's last known address.               
          Respondent argues that the notice of deficiency was mailed to               
          petitioner's last known address.  In docket Nos. 16948-97 and               





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