RILEY v. COMMISSIONER

Docket No. 1205-73.

32 T.C.M. 847 (1973)

T.C. Memo. 1973-180

Charles Patrick Riley v. Commissioner.

United States Tax Court.

Filed August 20, 1973.


Attorney(s) appearing for the Case

Charles L. Denaburg, Suite 1001, Brown Marx Bldg., Birmingham, Ala., and Gary Smith, for the petitioner. F. Patrick Matthews, for the respondent.


Memorandum Opinion

SCOTT, Judge:

The petition in this case which was filed on February 20, 1973, alleged that "The notice of deficiency (a copy of which is attached and marked Exhibit A) was mailed to petitioner on December 17, 1972." Exhibit A attached to the petition is a letter addressed to petitioner by the district director of internal revenue, Birmingham, Alabama which states in part:

NOTICE OF TERMINATION OF TAXABLE PERIOD

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