Peter Pettong and Chung-Yin Chiang - Page 2

                                          2                                           
          taxable years 1988 and 1989 was mailed to petitioners' last known           
          address and the petition was untimely filed.  A hearing was held            
          on this motion in Dallas, Texas.                                            
               Immediately prior to the hearing, petitioners filed a motion           
          to modify and amend the stipulation of facts.  On brief,                    
          respondent maintained that the motion consists solely of a                  
          restatement of facts previously admitted into evidence and, as a            
          result, filed no objection thereto.                                         
               We grant petitioners' motion to modify and amend the                   
          stipulation of facts because respondent has no objection thereto            
          and the modifications simply clarify facts previously agreed to             
          by the parties.  Accordingly, we need only address respondent's             
          motion to dismiss.                                                          
               Petitioners resided in Fort Worth, Texas, at the time their            
          petition was filed.                                                         
          Background                                                                  
               On January 14, 1991, the Internal Revenue Service (IRS)                
          District Office located in Fort Worth, Texas, mailed a letter to            
          petitioners at 7221 Francisco Drive, Fort Worth, Texas (the Fort            
          Worth address), asking their cooperation with the examination of            
          their 1988 and 1989 Federal income tax returns.  In a letter                
          addressed to the IRS dated January 17, 1991, petitioner Peter               
          Pettong Chiang (petitioner) explained that he and his family had            
          relocated to Athens, Tennessee, and was informed of the IRS                 
          letter by his sister, who remained at the Fort Worth address.  He           




Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011