King v. Commissioner
United States Tax Court
On Feb. 19, 1982, respondent's Dallas District Director's Office mailed a notice of deficiency for 1978 and 1979 to petitioners at the Mossvine Drive, Dallas address shown on their income tax returns for such years. Petitioners had moved from Mossvine Drive to Club Hill Drive, Dallas, on Oct. 1, 1980; the notice of deficiency was returned to the Dallas District Director's Office as undeliverable.
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On Feb. 19, 1982, respondent's Dallas District Director's Office mailed a notice of deficiency for 1978 and 1979 to petitioners at the Mossvine Drive, Dallas address shown on their income tax returns for such years. Petitioners had moved from Mossvine Drive to Club Hill Drive, Dallas, on Oct. 1, 1980; the notice of deficiency was returned to the Dallas District Director's Office as undeliverable. Prior to the issuance of the notice of deficiency, a protest letter was filed on behalf of petitioners in response to a 30-day letter, setting forth the Mossvine Drive address as petitioners'…
1Opinion of the Court
JACOBS, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and an addition to the tax as follows:
Sec. 6653(a)1 Year Deficiency
$4,776.70 1978 $95,533.92
5,373.30 1979 107,465.94
The matters presently, before us are the parties’ cross-motions to dismiss for lack of jurisdiction. Petitioners’ motion is premised upon respondent’s alleged failure to mail the notice of deficiency to petitioners’ last known address in accordance with section 6212(b)(1). Respondent asserts that the Court lacks jurisdiction because petitioners did not timely file their petition as required by…
2Cases cited10 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
- 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
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