Lester Johnson and Sherelle D. Brooks-Johnson - Page 10

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          particular, the Form 8821 was not a validly executed power of               
          attorney and therefore did not constitute a notification of                 
          change of address for petitioners.  Moreover, other than Ms.                
          Brooks-Johnson’s testimony, there is no evidence that she or Mr.            
          Johnson notified an examining revenue agent of their new address            
          before September 3, 1996.  We are not required to accept a                  
          taxpayer’s self-serving, undocumented testimony, Wood v.                    
          Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.              
          593 (1964), and, under the circumstances presented here, we do              
          not.                                                                        
               In sum, we hold that the 1994 notice of deficiency was                 
          mailed to petitioners’ last known address, and the petition                 
          (and/or amended petition) insofar as it purports to place in                
          dispute that year is untimely.  Accordingly, we shall grant                 
          respondent's motion to dismiss this case for lack of                        
          jurisdiction.                                                               
               In order to give effect to the foregoing,                              

                                                  An order will be issued             
                                             granting respondent's Motion             
                                             to Dismiss 1994 For Lack of              
                                             Jurisdiction.                            









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