Baptist v. Commissioner
United States Tax Court
Ps filed a motion to dismiss for lack of jurisdiction as to their 1985 and 1986 taxable years on the grounds that the notice of deficiency was not sent to their "last known address." R had received Ps' 1987 return reporting a new address 67 days prior to mailing the notice. R did not place the new address information into his computer until 105 days after receipt. In T.C.
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Ps filed a motion to dismiss for lack of jurisdiction as to their 1985 and 1986 taxable years on the grounds that the notice of deficiency was not sent to their "last known address." R had received Ps' 1987 return reporting a new address 67 days prior to mailing the notice. R did not place the new address information into his computer until 105 days after receipt. In T.C. Memo. 1990-280 we held that R, due to a lack of evidence or proof, did not show that he exercised "reasonable care and diligence" in processing new address information. R moved to open the record for new evidence, to vacate,…
1Opinion of the Court
ROBERT J. AND MARY E. BAPTIST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Baptist v. Commissioner
Docket No. 22854-89
United States Tax Court
T.C. Memo 1990-400; 1990 Tax Ct. Memo LEXIS 417; 60 T.C.M. (CCH) 315; T.C.M. (RIA) 90400;
July 30, 1990, Filed
Respondent's motions to vacate, open the records and reconsider will be denied.
Ps filed a motion to dismiss for lack of jurisdiction as to their 1985 and 1986 taxable years on the grounds that the notice of deficiency was not sent to their "last known address." R had received Ps' 1987 return reporting a new address 67 days prior to…
2Cases cited10 opinions
- Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
- Monge v. CommissionerUnited States Tax Court · 1989
- Frieling v. CommissionerUnited States Tax Court · 1983
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Abeles v. CommissionerUnited States Tax Court · 1988
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