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filed amended objections. In these documents, petitioner contends
that his petition was timely filed:
as to all Notices of Deficiency allegedly
issued by IRS [Internal Revenue Service] in
October, 1996 including F1040 1992, 1993 and
Section 4975 because of the language Petitioner
uses in said Petition and because the
Respondent had sufficient Notice that
Petitioner was contesting all Notices of
Deficiency whether or not said Notices were
attached to the Petition.
In addition, petitioner asserts that respondent's motion to dismiss
should be denied on the ground that the second and third deficiency
notices were not sent to petitioner's last known address. In this
regard, petitioner maintains that he was informed of the second and
third deficiency notices only when he received (on August 1, 1997)
respondent's motion to dismiss.
On September 22, 1997, the Court held a hearing on respondent's
motion to dismiss.
On October 20, 1997, petitioner filed a "Motion to Dismiss--
(F1040 1992 Income Taxes) (Section 4975 Excise Taxes Pre 1993)".
In this motion, petitioner contends that the mailing address used
by respondent to contact him should not have been the Hickory Hills
address with respect to the second and third deficiency notices.
Consequently, petitioner continues, the second and third deficiency
notices were improperly mailed and the period of limitations for
making a deficiency assessment expired with respect to his and his
wife's 1992 income tax liability as well as his liability for
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