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intended to rescind, or that petitioner consented to, rescission
of the notice of deficiency mailed to the Bay Harbor Island
address. Also, there is no evidence that respondent withdrew or
otherwise caused the notice of deficiency mailed to the Bay
Harbor Island address to be invalidated. The issuance of the
notice of deficiency on April 13, 1995, is of no consequence
because it was not mailed to petitioner’s last known address and
was not received.
To reflect the foregoing,
An order will be entered
granting respondent’s motion to
dismiss for lack of jurisdiction.
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Last modified: May 25, 2011