- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011