- 3 - 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 FederalPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011