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provided respondent with clear and concise notification that they
intended for respondent to correspond with them at any address
other than either the Hale St. address or the Girard St. address.
Because the notice of deficiency was mailed to petitioners
at their last known address, we shall grant respondent's Motion
to Dismiss for Lack of Jurisdiction.3
In order to reflect the foregoing,
An order will be entered
granting respondent's Motion to
Dismiss for Lack of Jurisdiction.
3 Although petitioners cannot pursue their case in this
Court, they are not without a legal remedy. In short,
petitioners may pay the tax, file a claim for refund with the
Internal Revenue Service, and if the claim is denied, sue for a
refund in the Federal District Court or the U.S. Court of Federal
Claims. See McCormick v. Commissioner, 55 T.C. 138, 142 (1970).
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Last modified: May 25, 2011