- 6 - known address. Petitioner received the notice of deficiency. He wrote a letter to Zobrist on May 20, 1986, in which he said that he was a limited partner in Winchester Oil and asked for advice. Petitioner attached a copy of the 1986 notice of deficiency to that letter. On July 25, 1986, Zobrist sent a letter to petitioner and Rothhammer informing them that a petition had been mailed on their behalf and enclosing a copy. The petition was filed on August 4, 1986, at docket No. 32146-86. 2. Tax Year 1980 (Docket No. 22961-88) On June 7, 1988, respondent sent a notice of deficiency for 1980 addressed to both petitioners at P.O. Box 886, Suffolk, Virginia 23434, petitioner’s last known address, and to both petitioners at Rothhammer’s Colorado Springs address. The U.S. Post Office returned to respondent the envelope containing the notice that had been sent to Suffolk, Virginia. The envelope was marked “undeliverable as addressed, no forwarding order on file.” Respondent sent to Covalt, and Covalt received, a copy of that notice of deficiency. On June 20, 1988, Covalt wrote a letter to Zobrist (copy to Rothhammer) stating that respondent had sent a notice of deficiency for 1980 to Rothhammer and petitioner and to ask Zobrist to contact Rothhammer. Covalt also wrote a letter to Robb (copy to Rothhammer) on June 20, 1988, in which he enclosed a copy of the notice of deficiency for 1980 to ensure that Robb knew that respondent had sent it to petitioner. On August 29, 1988, Berg signed the petition for taxablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011