Pyo v. Commissioner
United States Tax Court
On or about Apr. 13, 1981, the District Director of Internal Revenue at Los Angeles mailed a statutory notice of deficiency covering the taxable years 1976 and 1977 to petitioners at the address shown on their income tax returns for those years.
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On or about Apr. 13, 1981, the District Director of Internal Revenue at Los Angeles mailed a statutory notice of deficiency covering the taxable years 1976 and 1977 to petitioners at the address shown on their income tax returns for those years. Prior to this mailing, the same District Director's Office corresponded with petitioners on numerous occasions concerning their income tax liabilities for the taxable years 1978 and 1979 at another address shown on petitioners' income tax returns for these subsequent years. Petitioners did not receive the notice of deficiency mailed on Apr. 13, 1981,…
1Opinion of the Court
OPINION
Goffe, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income tax and additions to tax as follows:
Year . Deficiency in tax Negligence addition sec. 6653(a)1
1976 $23,816 $1,191
1977 13,125 656
This case is before the Court on the parties’ cross-motions to dismiss for lack of jurisdiction. Petitioners’ motion is premised upon the Commissioner’s alleged failure to mail the notice of deficiency to petitioners’ last known address in accordance with section 6212(b)(1). Respondent asserts that this Court lacks jurisdiction because petitioners did not file their petition…
2Cases cited29 opinions
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- 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
- Frieling v. CommissionerUnited States Tax Court · 1983
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