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This case is before the Court on respondent's Motion to
Dismiss for Lack of Jurisdiction, filed March 20, 2001. As
discussed in detail below, we shall grant respondent's motion.
Background
On January 19, 2000, respondent mailed a notice of
deficiency to petitioner determining a deficiency in her Federal
income tax for 1998 in the amount of $2,785 (the deficiency
notice for 1998). Also on January 19, 2000, respondent mailed a
notice of deficiency to petitioner determining a deficiency in
her Federal income tax for 1997 in the amount of $2,134 (the
deficiency notice for 1997).
Respondent sent both the deficiency notice for 1998 and the
deficiency notice for 1997 by certified mail addressed to
petitioner at 112 Bayview Drive, Grasonville, MD 21638 (the
Grasonville address). Petitioner received the deficiency notice
for 1997 shortly after it was mailed; in contrast, petitioner
does not recall receiving the deficiency notice for 1998 until
August 2000. According to respondent, the deficiency notice for
1998 was not returned to respondent by the U.S. Postal Service.
On April 20, 2000, petitioner timely filed a petition for
redetermination (assigned docket No. 4419-00S) contesting
respondent’s deficiency determination for 1997. Attached to the
petition as an exhibit was a copy of the deficiency notice for
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