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Respondent has offered no evidence to rebut the presumption
of delivery that results from petitioner's testimony. We find,
therefore, that petitioner timely filed his 1989 Federal income
tax return. It follows that the assessment and collection of the
deficiency here in dispute is barred because the notice of
deficiency was not issued within the period prescribed by section
6501(a).
To reflect the foregoing and the provisions of section
7459(e),
Decision will be
entered for petitioner.
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Last modified: May 25, 2011