MOLLET v. COMMISSIONER

Docket No. 3633-83.

82 T.C. 618 (1984)

MERLIN L. MOLLET, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 18, 1984.


Attorney(s) appearing for the Case

Shannon M. O'Toole, for the petitioner.

Dale L. Newland and Gerald W. Leland, for the respondent.


KÖRNER, Judge:

This matter is before the Court on cross-motions by the parties to dismiss for lack of jurisdiction. Petitioner's motion is based upon the alleged failure of respondent to send his statutory notice of deficiency with respect to the years 1978 and 1979 to petitioner at his last known address, as required by section 6212(b)(1).1 Respondent's motion to dismiss is based upon the alleged failure of petitioner to file...

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