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KOCHANOWSKI v. COMMISSIONER

Docket No. 10436-82.

45 T.C.M. 666 (1983)

T.C. Memo. 1983-72

Kenneth S. Kochanowski and Pamela A. Kochanowski v. Commissioner.

United States Tax Court.

Filed February 2, 1983.

Attorney(s) appearing for the Case

Gary E. Shoffner and Michael F. Sfregola, 4590 Mac Arthur Blvd., Newport Beach, Calif., for the petitioners. Valerie K. Liu, for the respondent.

Memorandum Opinion

SHIELDS, Judge:

Respondent determined a deficiency of $13,523 in petitioners' 1977 Federal income tax. The sole issue presented is whether respondent mailed his notice of deficiency to petitioners' last known address within the meaning of section 6212(b)(1).1 The parties agree that if the requirements of section 6212(b)(1) were satisfied, the petition herein was untimely filed under section 6213(a), depriving...

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