Wilburn C. Hall, Jr. - Page 1

          T.C. Memo. 1996-27                                                          

                               UNITED STATES TAX COURT                                

                         WILBURN C. HALL, JR., Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No. 26125-90.           Filed January 25, 1996.                      

          Petitioner (P) was involved in a number of businesses,                      
          most of which were incorporated.  P reported on his tax                     
          returns large business losses for the years in issue, most                  
          of which appear to arise from expenses of his corporations.                 
          P had gross receipts, interest, and royalty income in excess                
          of what he reported on his tax returns.                                     
          P filed his tax returns for 1982 through 1986 late.                         
          Respondent mailed a notice of deficiency to P less than 3                   
          years after any of these tax returns were filed.  This                      
          notice of deficiency was returned by the U.S. Postal                        
          Service.  P wrote to respondent, stating that any notice of                 
          deficiency should be sent to him at two addresses--(1) the                  
          one respondent had already used and (2) another address.                    
          Respondent then mailed a photocopy of the notice of                         
          deficiency to P at the other address.  By this time, it was                 
          more than 3 years after P had filed his tax returns for                     
          1982, 1983, and 1984.  P filed his petition with this Court                 
          within 90 days after the first mailing of the notice of                     
          1.  Held:  The first mailing of the notice of                               
          deficiency was to P's last known address, and was timely.                   
          Secs. 6212(b)(1), 6501(a), I.R.C. 1986.                                     

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