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income tax for 1990. The notice of deficiency was mailed to
petitioner at the Crystal Drive address. The envelope bearing
the notice of deficiency was returned to respondent marked
"UNABLE TO FORWARD".
According to petitioner, he moved from the Crystal Drive
address on approximately September 1, 1991. Petitioner further
asserts that he resided at 4875 Santa Cruz Avenue, San Diego, CA
92107 between that date until his move to 4776 Bayard Street, San
Diego, CA 92109 (the Bayard Street address) on February 1, 1992.
Petitioner notified respondent of his change of address to the
Bayard Street address sometime in March 1995. Petitioner filed
his tax returns for 1991 and 1993 on July 21, 1995, listing his
address as the Bayard Street address. Petitioner did not file a
tax return for 1992. Consequently, petitioner's 1990 tax return
was the last tax return filed by petitioner prior to the issuance
of the notice of deficiency for 1990. Petitioner did not provide
respondent with a notice of a new address during the period April
15, 1991, until March 1995.
On August 10, 1995, respondent mailed a notice of deficiency
to petitioner determining a deficiency of $3,101 in his Federal
income tax for 1992, as well as an addition to tax under section
6651(a) in the amount of $775.25 and an addition to tax under
section 6654(a) in the amount of $135.20. The notice of
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