Robert G. Honts - Page 7

                  Section 6501(a) provides that the amount of any deficiency                               
            in income tax shall be assessed within 3 years after the return                                
            was filed.  Section 6503(a) provides, however, that the running                                
            of the 3-year period of limitations is suspended by "the mailing                               
            of a notice under section 6212(a)."  Section 6212(a) authorizes                                
            the Secretary or his delegate, upon determining that there is a                                
            deficiency in income tax, to send a notice of deficiency "to the                               
            taxpayer by certified mail or registered mail."  Section                                       
            6212(b)(1) provides that a notice of deficiency, in respect of an                              
            income tax, "shall be sufficient" if it is "mailed to the                                      
            taxpayer at his last known address".  Generally, the Commissioner                              
            has no duty to effectuate delivery of the notice after it is                                   
            mailed.  Monge v. Commissioner, 93 T.C. 22, 33 (1989).                                         
                  Neither section 6212 nor the regulation promulgated                                      
            thereunder, section 301.6212-1, Proced. & Admin. Regs., defines                                
            what constitutes a taxpayer's "last known address".  We have                                   
            defined it as the taxpayer's last permanent address or legal                                   
            residence known by the Commissioner, or the last known temporary                               
            address of a definite duration to which the taxpayer has directed                              
            the Commissioner to send all communications during such period.                                
            Weinroth v. Commissioner, 74 T.C. 430, 435 (1980); Alta Sierra                                 
            Vista, Inc. v. Commissioner, 62 T.C. 367, 374 (1974), affd.                                    
            without published opinion 538 F.2d 334 (9th Cir. 1976).  Stated                                
            otherwise, it is the address to which, in light of all the                                     

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