Robert F. McPartlin and Geraldine McPartlin v. Commissioner of the Internal Revenue Service

MAROVITZ, Senior District Judge.

Petitioners Robert F. McPartlin and his wife Geraldine McPartlin appeal an order of the United States Tax Court dismissing their petition for a redetermination of a tax deficiency. The tax deficiency was determined by respondent Commissioner of the Internal Revenue Service (the “Commissioner”) with respect to petitioners’ 1971 tax return. On April 13,1978, the Commissioner mailed a statutory notice of deficiency to the address appearing on petitioners’ 1971 return. Petitioners, who had moved since the filing of their 1971 return, did not receive any notice that…