St. Joseph Lease Capital Corporation - Page 8

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          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 decide                 




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