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SCHEIDT v. COMMISSIONER

Docket No. 22537-82.

49 T.C.M. 1501 (1985)

T.C. Memo. 1985-235

William B. Scheidt and Wanda C. Scheidt v. Commissioner.

United States Tax Court.

Filed May 15, 1985.

Attorney(s) appearing for the Case

Michael W. Thom, 3030 Northwest Expressway, Oklahoma City, Okla., for the petitioners. Juandell D. Glass, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

This case is before the Court on petitioners' Motion to Dismiss for Lack of Jurisdiction and Motion for Summary Judgment. Petitioners argue that the notice of deficiency for 1978 is invalid on two grounds: (1) the deficiency notice was not sent to petitioners' last known address within the meaning of section 6212 (b)(1) and (2) the deficiency notice was "remailed" by respondent after the expiration of...

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