William M. Hezel - Page 5

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          "last known address."  Sec. 6212(b); Frieling v. Commissioner, 81           
          T.C. 42, 52 (1983).  The taxpayer, in turn, has 90 days (or 150             
          days if the notice is addressed to a person outside of the United           
          States) from the date that the notice of deficiency is mailed to            
          file a petition in this Court for a redetermination of the                  
          deficiency.  Sec. 6213(a).                                                  
          There is no dispute that respondent mailed the notices of                   
          deficiency to petitioner at his last known address on June 23,              
          1995.  Further, petitioner admits that he received the notices of           
          deficiency and, in early July 1995, returned them to respondent             
          marked "Refusal For Cause Without Dishonor U.C.C. 3-501".                   
          Petitioner did not file his petitions for redetermination with              
          the Court until September 25, 1996--some 15 months after the                
          notices of deficiency were mailed.  Thus, it is evident that                
          petitioner did not timely file his petitions for redetermination.           
          Consequently, we will dismiss these cases for lack of                       
          jurisdiction on the ground that petitioner failed to file his               
          petitions within the 90-day time period prescribed in section               

          2  Although petitioner cannot pursue his case in this Court,                
          he is not without a remedy.  In short, petitioner may pay the               
          tax, file a claim for refund with the Internal Revenue Service,             
          and if the claim is denied, sue for a refund in the Federal                 
          District Court or the U.S. Court of Federal Claims.  See                    
          McCormick v. Commissioner, 55 T.C. 138, 142 (1970).                         

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