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SICKER v. C.I.R.

No. 86-5498 Non-Argument Calendar.

815 F.2d 1400 (1987)

Charles R. SICKER, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

May 1, 1987.

Attorney(s) appearing for the Case

Michael L. Paup, Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Roger M. Olsen, Ann Belanger Druney, James H. Love, Washington, D.C., for respondent-appellee.

Before HILL, KRAVITCH and CLARK, Circuit Judges.

HILL, Circuit Judge:

This appeal involves the timeliness of a taxpayer's filing of a petition for redetermination of deficiency. On July 29, 1985, the Internal Revenue Service mailed appellant Charles Sicker a notice of deficiency. See 26 U.S.C. § 6212(a) (1982). This notice was mailed to Rt. 1, Box 1635, O'Keechobee, FL 33472. Appellant's last known address, however, was Rt. 1, Box 1633, O'Keechobee, FL 33472.

Before the Tax Court...

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