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ROSE v. COMMISSIONER

Docket No. 9086-76.

36 T.C.M. 1134 (1977)

T.C. Memo. 1977-285

James L. Rose v. Commissioner.

United States Tax Court.

Filed August 23, 1977.

Attorney(s) appearing for the Case

F. Pen Cosby, Suite 1925, One Indiana Square, Indianapolis, Ind., for the petitioner. Richard E. Trogolo, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction. The question involved is whether respondent mailed the notice of deficiency herein to petitioner's "last known address" as that phrase is used in section 6212(b)(1)1. If so, the petition herein was not timely filed and respondent's motion must be granted.

Findings of Fact<...

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