Fred Sebastian - Page 2




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               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.                                                                   







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