- 5 - On July 27, 2001, respondent filed a motion to extend further the time to respond to petitioner’s motion. Respondent’s motion stated that respondent’s records indicated that the last return filed by petitioner prior to 1996 was for 1985, that petitioner had several address changes, and that respondent was attempting to retrieve documents that would show the addresses for petitioner as of the dates the notices of deficiency were mailed. The Court granted respondent’s motion and ordered respondent to respond by September 14, 2001. On September 6, 2001, respondent sent petitioner a certificate of release of Federal tax lien, which petitioner recorded on September 27, 2001. On September 18, 2001, respondent filed a notice of no objection to petitioner’s motion to dismiss for lack of jurisdiction. Respondent’s notice stated that respondent did not object to petitioner’s motion to dismiss for lack of jurisdiction with respect to 1987, 1988, 1991, 1992, 1993, and 1994 on the ground that the notices of deficiency were not mailed to petitioner’s last known address. Respondent moved to dismiss as to 1989 and 1990 on the ground that respondent had not made any determination of a deficiency in petitioner’s income tax for either of those years. On September 19, 2001, we granted petitioner’s motion as to 1987, 1988, 1991, 1992, 1993, and 1994 on the ground that the notices of deficiency for those years werePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011