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 the
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