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3. 1988 and 1993 Through 1995
On July 9, 1997, respondent mailed to petitioner a notice of
deficiency determining deficiencies in petitioner’s Federal
income taxes for 1988, 1993, and 1994, in the amounts of $9,615,
$24,730, and $27,424, respectively, and additions to tax under
sections 6651(a)(1) and 6654(a) for 1993 and 1994. On July 9,
1997, respondent also mailed to petitioner a notice of deficiency
determining a deficiency in petitioner’s Federal income tax for
1995 in the amount of $29,506 and additions to tax under sections
6651(a)(1) and 6654(a). Both of the foregoing notices of
deficiency were mailed to petitioner at the DalRich Village
address.
On July 9, 1997, respondent mailed to Mr. Kotmair a copy of
the two above-described notices of deficiency issued to
petitioner.
By letter dated August 28, 1997, Mr. Kotmair wrote to
respondent acknowledging that petitioner had received the notices
of deficiency for 1988 and 1993 through 1995. Mr. Kotmair’s
letter listed petitioner’s address as the DalRich Village
address. Mr. Kotmair’s letter included as an attachment a third
document entitled “PRIVACY ACT RELEASE FORM AND POWER OF
ATTORNEY”, executed by petitioner under oath before a notary
public on July 23, 1997. This document listed petitioner’s
address as the DalRich Village address. Petitioner failed to
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