Riehm v. Tax Appeals Tribunal

— Casey, J.

On or about April 10, 1986, the Department of Taxation and Finance sent a notice of deficiency to petitioners which concerned the 1982 and 1983 tax years. Although the notice was sent to petitioners’ former address, petitioners concede that they received the notice but assert that it was not received until after April 15, 1986. Petitioners timely filed a petition for redetermination, claiming that the notice of deficiency was ineffective as to the 1982 tax year because it was misaddressed and was not received within three years of the filing of the 1982 tax return. Petitioners also…