Peter Pettong and Chung-Yin Chiang - Page 9

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          address.  On the Form 8822 attached to petitioners' Motion to               
          Submit Taxpayers' Filing Photocopy of Form 8822 Supplemental                
          Pleading/Evidence to Petitioners' Simultaneous Briefs filed                 
          September 14, 1995, petitioners placed the following                        
          acknowledgment:                                                             
               Supplemental Pleading/Evidence, the owners' completed                  
               photocopy of Form 8822 as attached (The original was                   
               sent to IRS Office, Austin, Texas 73301 on April 10,                   
               1993) shall be honorably  submitted for legal review,                  
               pursuant to the Rule 41 of U.S. Tax Court Rules of                     
               Practice and Procedure for the Docket No. 3642-94.                     
                    We have hereunto signed our names this 6th day of                 
               September 1995.                                                        
          Petitioners had their signatures notarized.  Petitioners' motion            
          was denied on September 18, 1995.                                           
               Based on the record in this case, we find that respondent              
          sent the notice of deficiency for 1988 and 1989 to petitioners'             
          last known address.  Petitioners' contention that respondent                
          should have been aware of the Oliver Street address is untenable.           
          The Fort Worth address appears to have been the one constant                
          factor in respondent's dealings with these peripatetic                      
          petitioners in that petitioner's sister resided at that address             
          at all times relevant herein, petitioner admits receiving actual            
          notice of all correspondence sent there with the sole exception             
          of the notice of deficiency, and on numerous documents filed with           
          the IRS, including their most recently filed return prior to the            
          issuance of the notice of deficiency, petitioners listed the Fort           
          Worth address as their residence.  Because the notice was not               




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