- 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 taxable
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011