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SCHAEFER v. COMMISSIONER

Docket No. 19819-89.

62 T.C.M. 635 (1991)

T.C. Memo. 1991-426

Walter A. Schaefer v. Commissioner.

United States Tax Court.

Filed August 28, 1991.

Attorney(s) appearing for the Case

Larry N. Johnson, 1011 Western Ave., Seattle, Wash., for the petitioner.

Thomas N. Tomashek, for the respondent.

Memorandum Opinion

FAY, Judge:

On April 16, 1990, in a Memorandum Opinion [Dec. 46,529(M)] (T.C. Memo. 1990-195), we granted petitioner's Motion to Dismiss for Lack of Jurisdiction, holding that respondent's notice of deficiency was invalid because it was not mailed to petitioner at his last-known address. On May 21, 1990, petitioner filed petitioner's Motion for an Award of Reasonable Litigation Costs pursuant to section...

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