- 8 - Service Center. That Form 8822 stated that petitioner's new address was the North Lee Street Address. Petition The petition was hand delivered to the Court on January 3, 1995. Discussion With exceptions not here relevant, section 6501 provides a 3-year period from the time a return is filed for the assessment or collection (without assessment) of any tax, including income taxes (the period of limitations). The running of the period of limitations, however, is suspended under section 6503(a)(1) by “the mailing of a notice under section 6212(a)”. Section 6212(a) authorizes the Secretary, upon determining that there is a deficiency in income tax, to send a notice of deficiency “to the taxpayer by certified or registered mail.” Section 6212(b)(1) provides that a notice of deficiency in respect of an income tax “shall be sufficient” if it is “mailed to the taxpayer at his last known address”. Petitioner’s income tax returns for the years in question were filed on October 15, 1991, and the October 6 notice was sent to petitioner by certified mail well within the period of limitations. If any of the three addresses to which the October 6 notice was addressed was petitioner’s last known address, then the October 6 notice is presumptively sufficient and petitioner’s motion must be denied. We need not decidePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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