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Background
On or before April 15, 2000, petitioner filed Form 1040A,
U.S. Individual Income Tax Return, for the taxable year 1999. On
this return, petitioner listed her address as “725 First Street,
New London, MO 63459" (the 725 address).1
On or before April 15, 2001, petitioner filed Form 1040A for
the taxable year 2000. On this return, petitioner again listed
her address as the 725 address.2
On September 19, 2001, respondent sent petitioner a notice
of deficiency. In the notice, respondent determined a deficiency
in petitioner’s Federal income tax for the taxable year 1999 in
the amount of $3,831. Respondent sent the notice by certified
mail addressed to petitioner at the 725 address.
On January 22, 2002, the Court received and filed
petitioner’s petition for redetermination in respect of the
aforementioned notice of deficiency. The petition was received
in an envelope postmarked December 19, 2001, from Woodridge,
1 Petitioner attached to her 1999 return a Form W-2, Wage
and Tax Statement, and a Form 1099-R, Distributions from
Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs,
Insurance Contracts, etc. Each of these two latter forms listed
petitioner’s address as “725 E. 1st St., New London, MO 63459”.
In the context of the present case, we regard this latter address
as the equivalent of the 725 address.
2 Petitioner attached to her 2000 return a Form W-2 and a
Form 1099-R. The Form W-2 listed petitioner’s address as “725 E.
1st St., New London, MO 63459”. The Form 1099-R listed
petitioner’s address as a box number in New London, MO 63459.
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Last modified: May 25, 2011