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and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
COUVILLION, Special Trial Judge: This case is before the
Court on petitioners' Motion to Dismiss for Lack of Jurisdiction,
on the ground that no valid notice of deficiency was mailed to
petitioners, and respondent's cross Motion to Dismiss for Lack of
Jurisdiction, on the ground that the petition was not timely
filed under section 6213(a). A hearing was held on the motions,
at which time evidence was adduced. In addition, some of the
facts were stipulated, and those facts with the annexed exhibits
are so found and are incorporated herein by reference. In the
notice of deficiency, respondent determined the following
deficiencies and additions to tax with respect to petitioners'
tax years as indicated:
Additions to Tax
Year Deficiency Sec. 6651 Sec. 6653(a)1 Sec. 6661
1982 $1,912 $478 $96 --
1983 39,739 9,935 1,987 $9,935
1984 58,887 14,722 2,944 14,722
1985 13,453 3,363 673 3,363
1986 50,112 12,528 2,506 12,528
1987 626 157 31 --
1 Additions to tax (50 percent of interest due) under sec.
6653(a)(1)(B) and/or sec. 6653(a)(2) will be determined.
At the time the petition was filed, petitioners' legal residence
was Central Point, Oregon; however, the motions before the Court
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