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before and several months after the notice was issued and mailed
to petitioner on January 5, 1994. Respondent’s records do not
indicate that the form was received prior to the issuance of the
notice, and petitioner does not contend that he otherwise
provided clear and concise notice to respondent that his address
had changed from that shown on his most recently filed return.
Nothing else in the record suggests that any event occurred that
would otherwise have put respondent on notice that petitioner’s
last known address changed from the San Leandro address to the
Hayward address before the notice was issued. The San Leandro
address is therefore petitioner’s last known address within the
meaning of section 6212, and the notice was properly mailed to
him at that address. See Abeles v. Commissioner, 91 T.C. 1019
(1988).
Because the petition in this case was not filed within the
period prescribed by section 6213(a), respondent’s motion to
dismiss for lack of jurisdiction will be granted upon that
ground.
To reflect the foregoing,
An appropriate order
dismissing this case for lack
of jurisdiction will be
entered.
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