- 4 - certified mail.2 Accordingly, we conclude that the notice is valid and shall deny petitioner's motion to dismiss for lack of jurisdiction. An appropriate order will be issued. 2 Petitioner filed a motion for the production of documents on Apr. 2, 1998, in which he again argues that this case should be dismissed because respondent has offered no evidence showing that petitioner signed for the notice of deficiency when it was delivered. Petitioner also requests that respondent produce the documents used to calculate petitioner's deficiency. In this opinion we address only the issue of jurisdiction. Because we conclude that we have jurisdiction, issues concerning the correctness of respondent’s determination would be considered in a later proceeding.Page: Previous 1 2 3 4
Last modified: May 25, 2011