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MULVANIA v. COMMISSIONER

Docket No. 12671-82.

81 T.C. 65 (1983)

RICHARD L. MULVANIA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 20, 1983.

Attorney(s) appearing for the Case

Paul Frederic Marx, for the petitioner.

Marshall W. Taylor, for the respondent.

SIMPSON, Judge:

This matter is before us on the parties' cross motions to dismiss for lack of jurisdiction. The petitioner claims that the notice of deficiency was invalid because it had not been mailed to him at his last known address. Sec. 6212(b)(1), I.R.C. 1954.1 The Commissioner claims that the petition was not filed within 90 days after the mailing of the notice of deficiency. Sec. 6213(a). At the conclusion of the hearing...

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