Docket No. 3642-94.

72 T.C.M. 391 (1996)

T.C. Memo. 1996-377

Peter Pettong and Chung-Yin Chiang v. Commissioner.

United States Tax Court.

Filed August 15, 1996.

Attorney(s) appearing for the Case

Peter Pettong Chiang, pro se. Stephanie Jensen, for the respondent.


GOLDBERG, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 183.1 This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent moved for dismissal on the grounds that the notice of deficiency for taxable years 1988 and 1989 was mailed to petitioners' last known address and the petition was untimely...

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