Terrell v. Commissioner

PRADO, Circuit Judge:

Pamela R. Terrell appeals the Tax Court’s order dismissing her petition for lack of jurisdiction. The Tax Court found it lacked jurisdiction because Terrell filed her petition more than ninety days after the Commissioner of Internal Revenue (“Commissioner”) sent her a Notice of Final Determination (“Notice”). Terrell argues that because the Commissioner did not send the Notice to her “last known address,” as required by I.R.C. § 6015(e), this Court should find her petition timely as it was filed within ninety days of the Internal Revenue Service (“IRS”) mailing the Notice…