BLAIR v. COMMISSIONER

Docket No. 12081-88.

57 T.C.M. 1396 (1989)

T.C. Memo. 1989-454

Craig D. Blair v. Commissioner.

United States Tax Court.

Filed August 28, 1989.


Attorney(s) appearing for the Case

John Gigounas and Edward B. Simpson, 50 California St., San Francisco, Calif., for the petitioner. Sheila Olaksen, for the respondent.


Memorandum Findings of Fact and Opinion

GERBER, Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent contends that petitioner did not file a petition within 90 days. Petitioner counters that respondent failed to prove mailing of the notice of deficiency and/or that the notice was not mailed to petitioner's "last known address." Petitioner does not contend that a petition was timely filed.

Findings...

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