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Although petitioner contends that he did not receive the
notice of deficiency for 1983, the record shows that he did.3 On
September 12, 1990, petitioner filed an imperfect petition with
the Court (assigned docket No. 20618-90). On January 10, 1991,
the Court entered an Order of Dismissal for Lack of Jurisdiction
in that docket on the ground that petitioner had failed to file a
proper amended petition or pay the requisite filing fee within
the time prescribed by the Court. Although the Court, pursuant
to its normal procedure, has destroyed all of its records in
docket No. 20618-90 with the exception of the above-referenced
order of dismissal, both the Court’s docket record and
respondent's records show that the Court served respondent with a
copy of the petition on September 17, 1990. Respondent’s records
also show that attached as an exhibit to the copy of the petition
served on respondent were the first two pages of the notice of
deficiency dated June 15, 1990. In serving petitions on
respondent, see Rule 21(b)(1), it has long been the Court’s
practice to photocopy and serve at least the letter portion of
any notice of deficiency that accompanies the petition.
Petitioner did not file any notice of appeal from the
Court’s order of dismissal. Accordingly, such order has long
3 We note that the notice of deficiency for 1983 was mailed
to petitioner at the same Eufaula, Alabama, address that
petitioner had used in the docketed cases described above for
1981 and 1982 and the same address that petitioner is using in
the instant case.
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