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In sum, we conclude that respondent failed to mail the
notice of deficiency concerning petitioner's tax liability for
1990 to petitioner's last known address. Accordingly, we will
deny respondent's motion to dismiss and to strike as to the
taxable year 1990, and we will grant petitioner's motion to
dismiss as to the taxable year 1990, as supplemented, on the
ground that the notice of deficiency for that year is invalid
under section 6212.
To reflect the foregoing,
An order will be issued
denying respondent's Motion to
Dismiss for Lack of Jurisdiction
and to Strike as to the Taxable
Year 1990 and granting petitioner's
Cross-Motion to Dismiss for Lack of
Jurisdiction as to the Taxable Year
1990, as Supplemented.
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