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1997. The petition reflects petitioner’s address as 1462 Stoney
Point Way, Baltimore, Maryland 21226 (the Baltimore address).
On February 9, 2001, petitioner filed a petition for
redetermination (assigned docket No. 1601-01S, i.e., the instant
case) contesting respondent’s deficiency determination for 1998.
Attached to the petition as exhibits were copies of collection
notices relating to the taxable year 1998 that were sent to
petitioner at the Baltimore address. The petition reflects
petitioner’s address as 8103 Ventnor Road, Pasadena, Maryland
21122. The petition arrived at the Court in an envelope bearing
a U.S. Postal Service postmark date of February 7, 2001.
As indicated, respondent filed a Motion to Dismiss for Lack
of Jurisdiction on March 20, 2001. In the motion, respondent
contends that this case should be dismissed for lack of
jurisdiction on the ground that the petition was not filed within
the time prescribed by section 6213(a) or section 7502.
Petitioner filed an objection to respondent's motion to
dismiss. In her objection, petitioner contends that respondent
failed to mail the deficiency notice for 1998 to her at the
correct address.
This matter was called for hearing at the Court's motions
session in Washington, D.C., on May 30, 2001. Petitioner and
counsel for respondent appeared and presented evidence. In
particular, respondent introduced copies of petitioner’s Federal
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