- 4 - mailed, petitioner resided at 120 South 9th Street, DeKalb, Illinois (the 9th Street address). Prior to the mailing of the notices, respondent had mailed 30-day letters addressed to petitioner at the 9th Street address. In response to the 30-day letters, petitioner filed an initial petition with this Court on May 1, 1995, prior to the issuance of any notices of deficiency. On May 9, respondent mailed the notices of deficiency to the 11th Street address, as previously indicated. On June 2, respondent sent petitioner a letter at the 9th Street address, advising (i) that his initial petition would have to be dismissed for lack of jurisdiction because it was filed before the notices of deficiency were issued, (ii) that the notices of deficiency had been issued on May 9, and (iii) that he had until August 7 to file a petition in response to the notices of deficiency. Petitioner admits receiving this letter. On August 7, 1995, the petition that initiated this case was filed, in which petitioner states that he "disagrees with the tax deficiencies for the years 1987-1988-1993 [sic] as set forth in the Notice of Deficiency dated May 9, 1995, a copy of which is lost." On August 18, the Court dismissed the May 1, 1995, petition. On September 27, 1995, respondent served on petitioner, by mailing to him at the 9th Street address, a copy of his answer in this case, to which were attached copies of the notices of deficiency for each year at issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011