and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE ARMEN, Special Trial Judge: This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction, filed December 23, 1996. Background Respondent mailed duplicate original notices of deficiency (the notice of deficiency) to petitioner on July 26, 1996. In the notice of deficiency, respondent determined that petitioner is liable for additions to tax for the taxable years and in the amounts as follows: Additions to Tax Penalty Year Sec. 6653(b) Sec. 6651(f) Sec. 6663 1988 $4,472.25 -- -- 1989 -- $10,953.75 -- 1990 -- 15,451.50 -- 1991 -- 11,513.25 -- 1992 -- 6,417.00 -- 1993 -- -- $828.75 1994 -- -- 2,616.00 Respondent mailed the notice of deficiency to petitioner at two different addresses: (1) RD1, Box 254, Chenango Forks, New York 13746 (the Chenango Forks address), and (2) #06471052, P.O. Box 2000, Unit 1, Lewisburg Camp, Lewisburg, Pennsylvania 17837 (the Lewisburg address). Respondent did not mail a copy of the notice of deficiency to any authorized representative. The notice of deficiency that was mailed to the Chenango Forks address is undated. The record does not reveal whether thePage: Previous 1 2 3 4 5 6 7 Next
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