Sarkissian v. Comm'r
United States Tax Court
R mailed to P duplicate notices of deficiency for P's 2007 tax year. The petition herein was not timely filed. R and P filed competing motions to dismiss for lack of jurisdiction. R seeks dismissal on the ground that the petition was not timely filed. P seeks dismissal on the grounds that the notice was invalid because R failed to send either notice to P's last known address and P did not receive notice in time to file a timely petition.
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R mailed to P duplicate notices of deficiency for P's 2007 tax year. The petition herein was not timely filed. R and P filed competing motions to dismiss for lack of jurisdiction. R seeks dismissal on the ground that the petition was not timely filed. P seeks dismissal on the grounds that the notice was invalid because R failed to send either notice to P's last known address and P did not receive notice in time to file a timely petition. Held: P received actual notice of the deficiency with ample time remaining to file a timely petition but failed to do so. Held, further: Because P failed to…
1Opinion of the Court
ARTHUR SARKISSIAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sarkissian v. Comm'r
Docket No. 27511-11.
United States Tax Court
T.C. Memo 2012-278; 2012 Tax Ct. Memo LEXIS 279; 104 T.C.M. (CCH) 389;
October 1, 2012, Filed
An appropriate order of dismissal for lack of jurisdiction will be entered.
R mailed to P duplicate notices of deficiency for P's 2007 tax year. The petition herein was not timely filed. R and P filed competing motions to dismiss for lack of jurisdiction. R seeks dismissal on the ground that the petition was not timely filed. P seeks dismissal on the grounds that…
2Cases cited28 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Monge v. CommissionerUnited States Tax Court · 1989
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Frieling v. CommissionerUnited States Tax Court · 1983
- Abeles v. CommissionerUnited States Tax Court · 1988
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