Jack Alban Koerner - Page 3

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            and $557.90, respectively.  The notice of deficiency was                                  
            addressed to petitioner at the Mt. Airy address.                                          
                  Petitioner was evicted from the Mt. Airy address in May                             
            1995.  Petitioner notified the Commissioner of his eviction by                            
            letter dated May 12, 1995, but did not provide the Commissioner                           
            with a new address until July 1995.  Petitioner's 1994 tax                                
            return, filed on or about January 31, 1996, lists his address as                          
            the Mt. Airy address.                                                                     
                  On March 4, 1996, respondent sent a letter to petitioner                            
            stating that a change was made to petitioner's account for the                            
            taxable year 1993 to reflect tax, penalties, and interest owing                           
            in the amount of $21,614.43.                                                              
            On May 6, 1996, petitioner filed a petition for                                           
            redetermination with the Court listing the years in dispute as                            
            1987 through 1994.  The petition arrived at the Court in an                               
            envelope bearing a U.S. Postal Service postmark date of May 3,                            
            1996.  Attached to the petition is a copy of respondent's March                           
            4, 1996, letter described above.  At the time the petition was                            
            filed, petitioner resided in Silver Spring, Maryland.                                     
            In response to the petition, respondent filed a Motion to                                 
            Dismiss for Lack of Jurisdiction asserting:  (1) The Court lacks                          
            jurisdiction with respect to the taxable years 1987, 1988, 1989,                          
            and 1994 on the ground that respondent did not issue a notice of                          
            deficiency to petitioner for those years; and (2) the Court lacks                         





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