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TADROS v. C.I.R.

No. 990, Docket 84-4174.

763 F.2d 89 (1985)

Makram A. TADROS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided May 29, 1985.

Attorney(s) appearing for the Case

Makram A. Tadros, pro se, New York City, for petitioner-appellant.

Patricia M. Bowman, Atty., Tax Div., Dept. of Justice, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Carleton D. Powell, Tax Div., Dept. of Justice, Washington, D.C., of counsel), for respondent-appellee.

Before MANSFIELD, KEARSE and PRATT, Circuit Judges.

GEORGE C. PRATT, Circuit Judge:

The sole issue on this appeal is whether a notice of deficiency was mailed to the taxpayer's "last known address" within the meaning of 26 U.S.C. § 6212(b)(1) so as to require him to file his petition for redetermination in the tax court within 90 days of the mailing. Because we agree with the court below that the taxpayer failed to provide the commissioner with a clear and concise notification of his change in address, we find...

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