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Illinois. Both the petition and the envelope in which it was
mailed list petitioner’s address as “712 First Street, New
London, MO 63459” (the 712 address). Attached to the petition is
a copy of the September 19, 2001, notice of deficiency bearing
the 725 address.
As stated above, respondent filed a Motion to Dismiss for
Lack of Jurisdiction. In the motion, respondent asserts that
this case should be dismissed for lack of jurisdiction on the
ground that the petition was not filed within the time prescribed
by section 6213(a) or section 7502.3
On March 26, 2002, petitioner filed a Notice of Objection to
respondent’s motion. In her objection, petitioner asserts, inter
alia, that the 725 address “does not exist.” Also in her
objection, petitioner lists her address as the 712 address;
however, in the “Certificate of Service” attached to her
objection, petitioner lists her address as the 725 address.
Pursuant to notice, respondent’s motion to dismiss was
called for hearing at the Motions Session in Washington, D.C. on
April 24, 2002. At that time, there was no appearance by or on
behalf of petitioner, nor did petitioner file a statement
pursuant to Rule 50(c), the provisions of which were referred to
in the Court’s Order calendaring respondent’s motion for hearing.
3 All section references are to the Internal Revenue Code,
as amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011