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
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