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WALLIN v. C.I.R.

No. 83-7244.

744 F.2d 674 (1984)

Eve C.W. WALLIN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

Decided August 28, 1984.

As Amended September 28, 1984.

Attorney(s) appearing for the Case

Jean S. Schanen, Schanen Law Firm, Inc., Wasilla, Alaska, for petitioner.

Richard Shipley, Regional Counsel, Seattle, Wash., for respondent.

Before CHOY, PREGERSON, and CANBY, Circuit Judges.

PREGERSON, Circuit Judge:

The Tax Court dismissed Eve C.W. Wallin's (Wallin's) petition for redetermination of tax deficiency as untimely. The Internal Revenue Service (IRS) sent a notice of tax deficiency to Wallin's former address although it had notice that Wallin had moved. Wallin did not receive the deficiency notice within the time limit allowed to file a petition for redetermination. The Tax Court ruled that the IRS exercised reasonable diligence in searching...

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