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BAPTIST v. COMMISSIONER

Docket No. 22854-89.

59 T.C.M. 799 (1990)

T.C. Memo. 1990-280

Robert J. and Mary E. Baptist v. Commissioner.

United States Tax Court.

Filed June 4, 1990.

Attorney(s) appearing for the Case

Leonard Thomas Bradt, for the petitioners. Terry W. Vincent, for the respondent.

Memorandum Opinion

GERBER, Judge:

The parties filed cross motions for dismissal for lack of jurisdiction. Petitioners contend that respondent failed to mail the statutory notice of deficiency to petitioners' "last known address" within the meaning of section 6212.1 Respondent contends that the petition was untimely. Our focus here is upon the concept of "last known address." More specifically, we consider the period of time within...

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