- 2 -
and all Rule references are to the Tax Court Rules of Practice
and Procedure. The Court agrees with and adopts the Special
Trial Judge's opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PAJAK, Special Trial Judge: This case is before the Court
on respondent's motion to dismiss for lack of jurisdiction.
Petitioner filed an opposition to respondent's motion and
respondent filed a response thereto. A hearing was held on
respondent's motion. The issue for decision is whether
petitioner filed his petition within the time prescribed by
section 6213(a).
Respondent determined a deficiency of $54,434 in
petitioner's Federal income tax for 1988, together with additions
to tax under sections 6651(a) and 6654 of $10,828 and $2,720.80,
respectively.
For clarity and convenience, we have combined our findings
of fact and opinion. Petitioner resided at the Federal Prison
Camp, Tilden, Three Rivers, Texas, at the time he filed his
petition.
On November 3, 1995, respondent sent, by certified mail,
duplicate notices of deficiency to petitioner at the following
addresses:
1) FCI Three Rivers 47424-079
P.O. Box 4000
Three Rivers, Texas 78071
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011