Case: Notice of Deficiency Was Invalid When the IRS Failed to Establish Mailing Procedure; Case Dismissed for Lack of Jurisdiction (T.C. Summ.)

The IRS’s notice of deficiency was invalid when it failed to establish that the notice was properly mailed, and there were no notices of deficiency or other determinations sufficient to confer jurisdiction for the other tax years at issue, the U.S. Tax Court held in a summary opinion. Petitioner, an individual, did not timely file his federal tax returns for tax years 2006 through 2008. The IRS prepared a substitute for return for Petitioner’s 2006 tax year and allegedly mailed a notice of deficiency in 2012. After Petitioner filed a petition with the Tax Court seeking review for the 2006 ...