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deficiency was 3402 Centinela Avenue, Los Angeles, California
90066.
Section 6501(a) provides that the amount of any deficiency
in income tax shall be assessed within 3 years after the return
is filed. Section 6503(a) provides, however, that the running of
the 3-year period of limitations is suspended by the mailing of a
notice of deficiency. Section 62122 authorizes the Secretary or
2 SEC. 6212. NOTICE OF DEFICIENCY.
(a) In General.--If the Secretary determines that
there is a deficiency in respect of any tax imposed by
subtitle A or B or chapter 41, 42, 43, or 44, he is
authorized to send notice of such deficiency to the
taxpayer by certified mail or registered mail.
(b) Address for Notice of Deficiency.--
(1) Income and gift taxes and certain excise
taxes.--In the absence of notice to the Secretary
under section 6903 of the existence of a fiduciary
relationship, notice of a deficiency in respect of
a tax imposed by subtitle A, chapter 12, chapter
42, chapter 43, or chapter 44 if mailed to the
taxpayer at his last known address, shall be
sufficient for purposes of subtitle A, chapter 12,
chapter 42, chapter 43, chapter 44, and this
chapter even if such taxpayer is deceased, or is
under a legal disability, or, in the case of a
corporation, has terminated its existence.
(2) Joint income tax return.--In the case of
a joint income tax return filed by husband and
wife, such notice of deficiency may be a single
joint notice, except that if the Secretary has
been notified by either spouse that separate
residences have been established, then, in lieu of
the single joint notice, a duplicate original of
the joint notice shall be sent by certified mail
or registered mail to each spouse at his last
known address.
(continued...)
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