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of which were sent by certified mail,5 to various Internal
Revenue Service offices. Letters dated June 15, 1991, October 5,
1992, October 18, 1992, December 12, 1992, March 14, 1995, July
23, 1995, October 4, 1995, and November 15, 1995, list the Summit
Avenue address as petitioner's address. The remaining letters
list the P.O. Box 5072 address as petitioner's address.
Of the letters attached to petitioner's motion that list the
P.O. Box 5072 address as petitioner's address, the earliest is
dated January 11, 1994. The second earliest is dated November
29, 1995.
Shortly after petitioner filed her motion to restrain,
respondent filed a Motion to Dismiss for Lack of Jurisdiction.6
Respondent's motion is premised on the ground that, for the
taxable years 1988, 1989, and 1991, the petition was not timely
filed within the time prescribed by section 6213(a) or section
7502. For the taxable year 1990, respondent's motion is premised
on the ground that respondent is unaware of any notice of
deficiency having been sent to petitioner for that year.7
5 The exhibits to petitioner's motion include copies of 41
domestic return receipts (PS Forms 3811) for certified mail sent
to various IRS offices.
6 Respondent also filed a Notice of Objection to
petitioner's motion on the ground that the Court lacks
jurisdiction in this case.
7 The record suggests that respondent accepted petitioner's
1990 return as filed and applied the refund claimed thereon to an
outstanding liability for some other taxable year.
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