Patrick Wayne Woods v. Commissioner Internal Revenue Service

967 F.2d 597 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Patrick Wayne WOODS, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 91-70588. United States Court of Appeals, Ninth Circuit. Submitted May 26, 1992. * Decided June 2, 1992. Before FARRIS, DAVID R. THOMPSON and FERNANDEZ, Circuit Judges. 1 MEMORANDUM ** 2 Patrick Wayne Woods appeals pro se the tax court's dismissal for lack of jurisdiction of his petition for a redetermination of tax deficiency for tax year 1983. The tax court found that Wood's petition was not timely filed, depriving the court of jurisdiction. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a) and affirm. 3 There is no dispute that Woods's petition for redetermination was untimely. Rather, Woods contends that the time for filing the petition for redetermination never commenced to run because the IRS did not send notice of the deficiency to his "last known address" at the prison where he was…