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