Douglas James Crawford - Page 4

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          deficiency for 1992 was mailed to petitioner at the Bayard Street           
          address.                                                                    
               Petitioner provided the Court with copies of Forms 1099R,              
          1099-DIV, 1099-INT, and W-2 for 1992 reflecting the Bayard Street           
          address.  Respondent advised the Court that an underreporter                
          transcript in 1992 reflected four different addresses in                    
          California for petitioner, none of which was the Crystal Drive              
          address.                                                                    
          On October 27, 1995, petitioner filed a petition with the                   
          Court seeking a redetermination of his tax liabilities for the              
          taxable years 1990 and 1992.2  The petition was delivered to the            
          Court in an envelope bearing a U.S. Postal Service postmark date            
          of October 24, 1995.  There is no dispute that the petition was             
          timely filed with respect to the notice of deficiency determining           
          a deficiency in petitioner's tax liability for 1992.                        
               After several months' delay (during which time respondent              
          conducted a search for the administrative file concerning                   
          petitioner's 1990 tax year), respondent filed her motion to                 
          dismiss for lack of jurisdiction and to strike as to the taxable            
          year 1990 asserting that petitioner failed to file his petition             
          within the 90-day period prescribed in section 6213(a).                     
          Petitioner responded by filing his own motion to dismiss for lack           


               2  At the time of filing the petition herein, petitioner               
          resided in San Diego, California.                                           




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