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FOLEY v. COMMISSIONER

Docket No. 28458-81.

45 T.C.M. 456 (1983)

T.C. Memo. 1983-3

James M. Foley, Jr. v. Commissioner.

United States Tax Court.

Filed January 4, 1983.

Attorney(s) appearing for the Case

Lloyd Taylor, 256 Montgomery, San Francisco, Calif., for the petitioner. Patricia Anne Golembiewski, for the respondent.

Memorandum Opinion

STERRETT, Judge:

This case is presently before the Court on both respondent's and petitioner's Motions to Dismiss for Lack of Jurisdiction filed pursuant to Rule 53, Tax Court Rules of Practice and Procedure.1 The sole issue for decision is whether respondent mailed the deficiency notice herein to petitioner at his "last known address" as that phrase is used in section 6212(b)(1), I.R.C. 1954.

Petitioner...

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