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Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts, first
supplemental stipulation of facts, and attached exhibits.
The petition in this case was timely filed on August 7,
1995. At the time of filing the petition, petitioner resided in
DeKalb, Illinois.
At the calendar call of this case, petitioner filed a motion
for summary judgment, asking the Court to "deny any reassessments
of taxes, interest, and penalties" for the years in issue on the
basis that respondent did not mail the notices of deficiency to
his correct address. We treat this motion as a motion to dismiss
for lack of jurisdiction. The Court took the motion under
advisement, and the parties have addressed it on brief. We now
deny petitioner's motion.
Petitioner attached several copies of documents to his
briefs as documents in support of his motion. These documents
include copies of cover pages of 30-day letters respondent sent
to petitioner dated February 8, 1995, and a copy of a letter
respondent sent to petitioner dated June 2, 1995.
Petitioner did not file tax returns for any of the years in
issue. Separate notices of deficiency, each covering one of the
years at issue, were mailed May 9, 1995, and addressed to
petitioner at 645 North 11th Street, DeKalb, Illinois (the 11th
Street address), a house where petitioner formerly resided but
which had been sold by him in 1989. At the time the notices were
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