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Thomas during a field visit at the Lightning View address. The
aforementioned revenue officers have no recollection of being
informed that petitioner was residing at the Rogers Avenue
address or that petitioner wanted correspondence to be mailed to
that address.
Petitioner was provided with a copy of the notice of
deficiency for 1978 by letter from Revenue Officer Jaecksch dated
November 10, 1988.
On February 24, 1998 (more than 14 years after the mailing
of the notice of deficiency and more than 9 years after
petitioner received a copy of the notice of deficiency),
petitioner filed a petition for redetermination with the Court.
The petition was hand-delivered to the Court.
As indicated, respondent filed a Motion to Dismiss for Lack
of Jurisdiction on the ground that the petition was not timely
filed. Petitioner filed an objection to respondent's motion
asserting that the notice of deficiency was not mailed to his
last known address.
This matter was called for hearing on two occasions at the
Court's motions sessions held in Washington, D.C. Counsel for
both parties appeared and presented evidence. Following the
evidentiary hearing, both parties filed memoranda with the Court
setting forth their respective positions.
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