David Bleavins v. Commissioner Internal Revenue Service

962 F.2d 13 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. David BLEAVINS, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 91-70507. United States Court of Appeals, Ninth Circuit. Submitted May 5, 1992 * Decided May 11, 1992. Before HUG, DAVID R. THOMPSON and FERNANDEZ, Circuit Judges. 1 MEMORANDUM ** 2 David Bleavins appeals the tax court's decision dismissing his petition for redetermination of tax deficiency for tax years 1982 through 1986. The tax court dismissed the petition for lack of jurisdiction because Bleavins had not filed his petition within 90 days of the issuance of the notice of deficiency. Bleavins contends that the notices of deficiency were not valid because they were not mailed to his last known address. We have jurisdiction pursuant 26 U.S.C. § 7482 (a) and affirm. 3 We review the issue of whether a notice of deficiency was mailed to a taxpayer's last known address under the clearly erroneous standard.…