- 7 - The Town of Gardiner had three postal routes and three letter carriers in 1992. Theresa Williams (Williams) has been the letter carrier for the postal route including Route 208 and the Sicari residence since approximately 1990. She worked throughout the month of October 1992 without missing a day for sick leave or vacation. During 1992, if certified mail was addressed to petitioners at the Route 208 address, Williams would deliver it to petitioners. Articles of mail marked with the Route 208 address did not need a rural box number designation for Williams to deliver them to petitioners in 1992. In accordance with the U.S. Postal Service Domestic Mail Manual (DMM), any records of the certified mail delivery maintained by the Gardiner Post Office were destroyed after 2 years. Petitioners never sent notice to respondent specifically informing her that the address on their most recent return no longer should be used or that they wanted a different address to be used for tax purposes. Discussion The jurisdiction of this Court is governed by statute. Sec. 7442. A valid notice of deficiency and a timely filed petition are essential to our deficiency jurisdiction. Rule 13(a), (c); Monge v. Commissioner, 93 T.C. 22, 27 (1989); Abeles v. Commissioner, 91 T.C. 1019, 1025 (1988). Under section 6212, a notice of deficiency is sufficient if it is mailed to the taxpayer's last known address by certified or registered mail.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011