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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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