BILL WRIGHT TOYOTA, INC. v. COMMISSIONER

Docket No. 22854-90.

63 T.C.M. 3146 (1992)

T.C. Memo. 1992-344

Bill Wright Toyota, Inc. v. Commissioner.

United States Tax Court.

Filed June 15, 1992.


Attorney(s) appearing for the Case

Stephen H. Boyle, 1430 Truxtun Ave., Bakersfield, Calif., for the petitioner. Terri A. Merriam, for the respondent.


Memorandum Opinion

NAMEROFF, Special Trial Judge:

This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction on the grounds of an untimely filed petition. Respondent contends the notice of deficiency for petitioner's table year ending October 31, 1986, was mailed via certified mail to petitioner's last known address on July 11, 1990, as evidenced by respondent's certified mailing list (Form 3877) and the notice

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