T.C. Memo. 2000-115
UNITED STATES TAX COURT
MICHAEL P. AND DOLORES A. GAM, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13223-98. Filed March 31, 2000.
R sent a notice of deficiency for 1995 to Ps. This
notice of deficiency was mailed to the address used by Ps on
their 1996 tax return, the last tax return Ps filed before
the notice of deficiency was issued, except that R placed
three additional digits at the end of the otherwise-correct
ZIP Code. Ps did not receive this notice of deficiency.
About 7 months later, Ps received a copy of this notice of
deficiency from R’s Taxpayer Advocate.
Held: Based on the evidence, the three additional
digits on the end of the ZIP Code in the address used to
mail the notice of deficiency did not affect the postal
processing of the notice of deficiency and, as a result, did
not render the address something other than Ps’ last known
address. Ps’ petition was not timely filed, and R’s motion
to dismiss is granted. See secs. 6212, 6213, I.R.C. 1986.
Michael P. and Dolores A. Gam, pro se.
Milton B. Blouke, for respondent.
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