RECHNITZER v. COMMISSIONER

Docket No. 4150-65.

26 T.C.M. 298 (1967)

T.C. Memo. 1967-55

Paul H. Rechnitzer and Katherine W. Rechnitzer v. Commissioner.

United States Tax Court.

Filed March 22, 1967.


Attorney(s) appearing for the Case

Robert E. Kovacevich, 518 Paulsen Bldg., Spokane, Wash., for the petitioners. Gary C. Randall, for the respondent.


Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the calendar year 1962 in the amount of $311.51.

The issues for decision are (1) whether the statutory notice was mailed to petitioners at their "last known address" within the meaning of section 6212(b)(1) of the Internal Revenue Code of 1954, or, in the alternative, whether in any event petitioners timely received such notice...

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