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By notice of deficiency dated December 14, 1995, respondent
determined a deficiency in petitioners' 1992 Federal income tax
in the amount of $23,842, plus an addition to tax under section
6651(a)(1) in the amount of $1,745 and an accuracy-related
penalty under section 6662(a) in the amount of $4,768. The
notice of deficiency was sent by certified mail to petitioners at
the Palms address. According to the certified mail receipt, the
deficiency notice was delivered by the U.S. Postal Service and
signed for on December 15, 1995.
In a letter dated December 14, 1995, Richard R. Orosco,
District Director of the Los Angeles Office of the Internal
Revenue Service (IRS), advised Ms. Steinhauer that materials
pertaining to the petitioners were being furnished to her
pursuant to a power of attorney on file with the IRS. A copy of
the notice of deficiency, clearly dated December 14, 1995 and
stamped "ORIGINAL", was attached to the letter. The envelope
containing this letter and the copy of the deficiency notice has
an illegible postmark date; however, the envelope and its
contents were stamped as "received" by Ms. Steinhauer on December
18, 1995. The copy of the deficiency notice was not sent by
certified mail or registered mail to Ms. Steinhauer.
On December 18, 1995, Ms. Steinhauer telephoned Cynthia
Lowden, assistant manager of the 90-day section of the Los
Angeles IRS Office, regarding the final date for filing a
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