- 11 - With regard to the notice of deficiency for 1997, this is not an instance of repeated contact by a taxpayer from a single address over a long period of time prior to the issuance of the notice of deficiency.6 In this case, it is not clear whether petitioner contacted the IRS prior to the mailing of the notice of deficiency for 1997.7 Furthermore, petitioner’s first letter to the IRS concerned questions regarding filing his income tax return for 1999. We hold that respondent mailed the notice of deficiency for 1997 to petitioner’s last known address and petitioner failed to timely file a petition for 1997. Accordingly, we shall grant the motion to dismiss with regard to 1997. To reflect the foregoing, An appropriate order will be issued. 6 In fact, after petitioner had established regular contact with respondent for a period of almost 2 years, respondent mailed the notice of deficiency for 1998 to petitioner at his prison address. 7 The Sept. 21, 1999, letter to petitioner in Susanville, Calif., is the earliest letter petitioner received from respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011