- 2 - Fred Sebastian, pro se. T. Richard Sealy III, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: This collection review case is before the Court on respondent’s motion to dismiss for lack of jurisdiction. The issue for decision is whether the notice of determination concerning collection action was mailed to petitioner’s last known address. FINDINGS OF FACT At the time the petition was filed, petitioner resided in Chaparral, New Mexico. The address petitioner provided on his petition was “864 Broadmoor, Chaparral, New Mexico, 41011.” The ZIP Code “41011" was crossed out and replaced by the handwritten notation “88081". Petitioner did not file a Federal tax return for any of the taxable years 1995 through 2004. On May 25, 2001, respondent mailed to petitioner Proposed Individual Income Tax Assessments for taxable years 1996, 1997, and 1999. On June 24, 2001, respondent received from petitioner a letter disputing the proposed assessments. Petitioner listed his address as “864 Broadmoor, Chaparral, NM 88021". Petitioner’s arguments regarding the assessments consisted solely of tax-protester rhetoric.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007