![]() Issues: For the Tax Court to have jurisdiction to hear a taxpayer's case, a taxpayer must petition the court for relief of a valid deficiency notice within 90 days of the date the notice was mailed to the taxpayer. 13, 2016, the taxpayers became aware of the deficiency notice and filed a petition to the Tax Court. 13, 2016, prior to the filing of their 2015 tax return, the IRS sent the Gregorys, by certified mail, a notice of deficiency to their Jersey City address that was subsequently returned to the IRS. They also used the new address in April 2016, when they submitted Form 4868 to extend the filing date for their 2015 income tax return. 15, 2015 however, when the couple submitted Form 2848 in November 2015, they used their new Rutherford address. The couple used the Jersey City address when they filed their 2014 federal income tax return on Oct. ![]() According to the court, the two forms submitted by the taxpayers were not returns and did not provide the IRS with clear and concise notification of a different address for purposes of updating the taxpayers' last known address.įacts: On June 30, 2015, Damian and Shayla Gregory moved from Jersey City, N.J., to Rutherford, N.J. ![]() Individual Income Tax Return, both sent to the IRS after the filing of their latest income tax return. The Tax Court held that a notice of deficiency sent to husband- and- wife taxpayers' previous home address shown on their latest filed tax return was valid, despite the fact they had listed their new address on Form 2848, Power of Attorney and Declaration of Representative, and Form 4868, Application for Automatic Extension of Time to File U.S.
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