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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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