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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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Last modified: November 10, 2007