- 7 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011