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GAW v. COMMISSIONER

Docket No. 8015-92.

66 T.C.M. 466 (1993)

T.C. Memo. 1993-379

Anthony Teong-Chan Gaw and Rosanna W. Gaw v. Commissioner.

United States Tax Court.

Filed August 24, 1993.

Attorney(s) appearing for the Case

Donald L. Feurzeig and John M. Youngquist, 650 California St., San Francisco, Calif., for the petitioners. Cynthia K. Hustad and Daniel P. Ramthun, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

This case is before us on the parties' cross-motions to dismiss for lack of jurisdiction. Respondent moves for dismissal on the ground that the petition was untimely under section 6213(a). Petitioners ask that the case be dismissed on the ground that the statutory notice of deficiency was not mailed to their last known address pursuant to section 6212(b). All...

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