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respondent to send copies of all
correspondence to both the first and
second accountants named on the form.
November 19, 1998 The IRS service center in Memphis
receives and processes the Form 2848.
January 28, 1999 Respondent issues three notices of
deficiency covering all 6 tax years.
Respondent sends these notices to the
Gallatin address. All are sent by
certified mail; two are returned to the
IRS as unclaimed, and there is no record
of what happened to the third.
July 1999 Petitioner receives statements of
account for each of the years in
question from the IRS, sent to him at
his Hendersonville address.
September 1999 Petitioner begins suggesting compromise
to resolve all years in question.
July 2000- Petitioner continues settlement talks,
April 2002 first with a revenue agent and then with
the IRS Appeals office.
June 10, 2002 Petitioner files petition. (In lieu of
the notices of deficiency, which he
still hasn’t received, he attaches the
revenue agent’s reports from August
1998).
Petitioner continues to be a resident of Tennessee, as he
was when he filed his petition. When the case neared trial in
Nashville, both parties moved to dismiss the petition for lack of
jurisdiction--petitioner on the ground that respondent never sent
a notice of deficiency to his last known address, and respondent
on the ground that petitioner filed his petition well outside our
90-day jurisdictional limit. The parties have stipulated or not
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