Jessie J. Chambers - Page 4

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            Springs address and that his mailing address was P.O. Box 220,                               
            Austell, Georgia 30001 (the Austell address).                                                
                  On August 17, 1995, petitioner filed his 1994 tax return                               
            listing the Lithia Springs address as his current address.                                   
            On September 15, 1995, respondent mailed a notice of                                         
            deficiency to petitioner determining deficiencies in, additions                              
            to, and accuracy-related penalties with respect to his Federal                               
            income taxes for 1991, 1992, and 1993 as follows:                                            
               Additions to Tax     Accuracy-Related Penalty                                             
            Year Deficiency  Sec. 6651(a) Sec. 6654        Sec. 6662                                     
            1991 $ 6,966       $1,082       $232               ---                                       
            1992   8,783         ---         ---             $1,757                                      
            1993  10,950        2,738        459               ---                                       
            Duplicate originals of the notice of deficiency were mailed to                               
            petitioner at the Lithia Springs address and the Austell address.                            
            On August 14, 1996, petitioner filed an imperfect petition                                   
            for redetermination with the Court contesting respondent's                                   
            determinations for the taxable years 1990, 1991, 1992, and 1993.                             
            The petition was delivered to the Court in a U.S. Postal Service                             
            Express Mail envelope bearing a U.S. Postal Service postmark date                            
            of August 13, 1996.3  Petitioner subsequently filed a proper                                 
            amended petition.                                                                            
            As indicated, respondent filed a Motion to Dismiss For Lack                                  
            of Jurisdiction alleging that petitioner failed to file his                                  


            3  At the time that the petition was filed, petitioner                                       
            resided at the Fayetteville, Georgia, address.                                               




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