T.C. Memo. 1999-314
UNITED STATES TAX COURT
STARVEST U.S., INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 16948-97, 17705-98, Filed September 23, 1999.
1372-99.
David Finkelstein, for petitioner.
William R. McCants, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COUVILLION, Special Trial Judge: These consolidated cases
are before the Court on the parties' motions to dismiss for lack
of jurisdiction. In docket No. 16948-97, petitioner moves to
dismiss on the ground that the notice of deficiency is invalid
because it was not mailed to petitioner's last known address.
Respondent argues that the notice of deficiency was mailed to
petitioner's last known address. In docket Nos. 16948-97 and
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