- 3 - 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 lacksPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011