Boardman v. Department of Revenue

CARL N. BYERS, Judge.

Plaintiff appeals from an assessment of personal income taxes for the year 1983. Defendant’s Opinion and Order No. 89-2306 dismissed plaintiff s appeal on the ground it was untimely. Plaintiff contends the statute of limitations should be tolled.

Plaintiff is engaged in the private practice of law. He did not file income tax returns for the years 1983, 1985 and 1986. Defendant sent a demand letter, dated February 9, 1988, to plaintiffs law office at the Glisan Street address. Defendant received no response and plaintiff testified he was not sure he received the demand.…