- 2 - agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PANUTHOS, Chief Special Trial Judge: This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. The issue for decision is whether petitioners are entitled to the 150-day period for filing a petition with this Court as provided in section 6213(a). Background The material facts in this case are not in dispute. On July 31, 1997, respondent mailed a notice of deficiency to petitioners regarding their 1991, 1992, and 1993 Federal income tax returns. Duplicate notices of deficiency were mailed to petitioners' home address at 14615 Wood Road, Riverside, California, and petitioner Robert Roberts' (hereinafter petitioner) business address at 18856 Van Buren Boulevard, Riverside, California.2 Petitioner received one of the duplicate notices of deficiency at his business on August 2, 1997. The record does not reflect whether the notice of deficiency mailed to petitioners' residence was received by them, nor is there any indication that said notice was returned to respondent undelivered. 2 The jointly filed Federal income tax returns in issue reflected petitioner Robert Roberts' business address (18856 Van Buren Boulevard).Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011