- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10
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