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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.
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