- 2 - agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PANUTHOS, Chief Special Trial Judge: This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction and petitioner's Motion To Restrain Assessment and Collection. The primary issue for decision is whether the Court has jurisdiction over the petition filed in this case. Background Petitioner did not file tax returns for the taxable years 1987 through 1993. However, during the period 1989 through 1995, petitioner sent a substantial amount of correspondence to various Internal Revenue Service (IRS) offices concerning his tax liabilities for 1987 and subsequent years. Through mid-1995, petitioner consistently listed his address on this correspondence as 6627 Christy Acres Circle, Mt. Airy, Maryland (the Mt. Airy address). On November 1, 1993, respondent mailed a notice of deficiency to petitioner determining a deficiency in his Federal income tax for 1990 in the amount of $8,481 and additions to tax under sections 6651(a) and 6654(a) in the amounts of $2,120.25 (...continued) in effect for the years in issue, unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011