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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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