Yusko v. Commissioner
United States Tax Court
R issued a notice of deficiency for the taxable year 1980 on Apr. 10, 1984. R directed the notice to the address shown on P's 1982 return which R believed to be P's last known address. See United States v. Zolla, 724 F.2d 808 (9th Cir. 1984). On or about Apr. 6, 1984, P filed his 1983 return showing a new address.
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R issued a notice of deficiency for the taxable year 1980 on Apr. 10, 1984. R directed the notice to the address shown on P's 1982 return which R believed to be P's last known address. See United States v. Zolla, 724 F.2d 808 (9th Cir. 1984). On or about Apr. 6, 1984, P filed his 1983 return showing a new address. The information shown on this return was posted to R's computer records on or about May 20, 1984. Held, the date upon which R has notice of information shown on a return is generally the date the information is posted to R's computer records, rather than the date the return is…
1Opinion of the Court
OPINION
WHITAKER, Judge-.
This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7456 of the Code.1 The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge-.
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction. We must determine whether the notice of deficiency was mailed to petitioner at his “last known address” within the meaning of section 6212(b). If so, we must also determine whether an error by respondent in…
2Cases cited15 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Pyo v. CommissionerUnited States Tax Court · 1984
- Weinroth v. CommissionerUnited States Tax Court · 1980
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3Cited by53 opinions
- Crowell v. CommissionerUnited States Tax Court · 1994
- Gerald D. Ward and Joan Ward (Deceased) v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Weber v. Comm'rUnited States Tax Court · 2004
- Winnett v. CommissionerUnited States Tax Court · 1991
- Zapara v. Comm'rUnited States Tax Court · 2005
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