- 6 - 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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011