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 deficiency. 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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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