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MULVANIA v. COMMISSIONER

Docket No. 7209-83.

47 T.C.M. 1187 (1984)

T.C. Memo. 1984-98

Richard L. Mulvania v. Commissioner.

United States Tax Court.

Filed February 29, 1984.

Attorney(s) appearing for the Case

Paul Frederic Marx, 400 MacArthur Blvd., Newport Beach, Calif., for the petitioner. Margaret Hebert, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

This matter is before the Court on the parties' cross-motions to dismiss for lack of jurisdiction. The petitioner contends that respondent did not mail to him a valid notice of deficiency under section 62121 for 1977 within the 3-year statute of limitations on assessments prescribed by section 6501(a) and that this Court, therefore, lacks jurisdiction. Respondent maintains...

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