Rayle v. Commissioner

ORDER

Merrick- Rayle appeals from the Tax Court’s dismissal of his small tax case. Because we lack jurisdiction over the appeal, we dismiss.

The Internal Revenue Service mailed a notice of deficiency to Rayle’s last known address on January 8, 2013, triggering a 90-day deadline for him to challenge the deficiency determination. See 26 U.S.C. *306§ 6213(a). The notice informed Rayle that he owed unpaid taxes and penalties for tax years 2009 and 2010, and that he could contest the IRS’s determination by filing a petition with the Tax Court by April 8, 2018 — 90 days after the notice of deficiency was…