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asserting that respondent did not mail the notices of deficiency
to his last known address.
Background
Respondent determined deficiencies of $1,024 and $1,931 in
petitioner’s Federal income taxes for 1993 and 1994,
respectively, and additions thereto of $188.50 and $164.50,
respectively, under section 6651(a). Respondent reflected these
determinations in notices of deficiency which he mailed to
petitioner on October 24, 1997, at the address of “P.O. Box 565,
Springfield, OR 97477". Petitioner petitioned the Court on
January 3, 2001, to redetermine the determinations set forth in
the notices of deficiency. At that time, he resided in the
Airways Heights Correction Center in Airway Heights, Washington.
Discussion
Respondent contends that this case should be dismissed as
the petition was not filed within the time prescribed by statute.
Petitioner contends that respondent mailed the notices of
deficiency to the wrong address and that he only received them on
October 22, 2000. Petitioner asserts that he has been
incarcerated since September 18, 1994.
Our jurisdiction to redetermine a deficiency depends upon
the issuance of a valid notice of deficiency and a timely filed
petition. See Rule 13(a), (c); Monge v. Commissioner, 93 T.C.
22, 27 (1989); Abeles v. Commissioner, 91 T.C. 1019, 1025 (1988);
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