Deborah F. Robinson - Page 10
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recently filed return, which also listed the Summit Avenue
address as petitioner's address.
To counter the foregoing, petitioner alleges that she
directed respondent by letters dated April 10, 1988, and March 3,
1989, to change her address from the Summit Avenue address to the
P.O. Box 5072 address. For the following reasons, however, we do
not find that the purported letters served to give respondent
clear and concise notice of a change of address.
First, respondent has no record of ever having received
either the purported letter dated April 10, 1988, or the
purported letter dated March 3, 1989. Although we can imagine
that one such letter might be misfiled by respondent, we question
whether two such letters would be misfiled, particularly in view
of the fact that petitioner's other correspondence seems to have
found its way into respondent's hands.
Second, it is petitioner's practice to send correspondence
to respondent by certified mail. However, there is no indication
that either the purported letter dated April 10, 1988, or the
purported letter dated March 3, 1989, was sent by certified mail.
We find this odd, given the fact that "for security reasons",
petitioner allegedly wanted her refund checks to be sent to the
P.O. Box 5072 address and not to the Summit Avenue address.
Third, petitioner's income tax returns for 1988, 1989, 1990,
and 1991 all listed petitioner's address as the Summit Avenue
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