Janice A. Plekan - Page 2

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          Dismiss for Lack of Jurisdiction.  Respondent moved for dismissal           
          on the grounds that the petition was not filed within the 90-day            
          period prescribed in section 6213(a).  Petitioner moved for                 
          dismissal on the grounds that the notices of deficiency are                 
          invalid because they were not mailed to her last known address as           
          required under section 6212.  Petitioner also filed a motion to             
          have the burden of proof shifted to respondent.  A hearing was              
          held on these motions in Portland, Oregon.  Petitioner's Motion             
          to Shift the Burden of Proof was denied at the hearing.                     
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits received into evidence            
          are incorporated herein by this reference.  Petitioner resided in           
          Portland, Oregon, at the time her petition was filed.                       
               Petitioner filed a Federal income tax return for the taxable           
          year 1979.  Petitioner was residing at 1865 N.W. 106th, Portland,           
          Oregon (her parents' address), at the time she filed her return             
          for 1979.  This is the address which was shown as petitioner's              
          address on her 1979 return.  Petitioner filed no return for 1980,           
          but filed a Federal income tax return for 1981.  Petitioner was             
          issued a refund check for overpaid income taxes for taxable year            
          1981.                                                                       
               Petitioner did not file returns for any of the taxable years           
          1982 through 1988.  Respondent prepared substitute-for-returns              
          for petitioner's taxable years 1983 and 1984, pursuant to section           





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