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In early August 1995, petitioner closed the Wilmington post
office box and moved to 4997 Creek Road, Lewiston, New York (the
Lewiston address).
On August 29, 1995, respondent mailed a letter to petitioner
at the Wilmington address stating that petitioner's tax returns
for 1990, 1991, 1992, and 1993 had been selected for audit and
requesting that petitioner appear at respondent's offices in
Wilmington on September 26, 1995. Petitioner maintains that he
did not receive this letter. Respondent's files do not indicate
that the letter was returned to respondent undelivered.
On September 27, 1995, respondent issued a second letter to
petitioner at the Wilmington address proposing adjustments to
petitioner's taxes for the years 1990, 1991, 1992, and 1993.
Petitioner maintains that he did not receive this letter.
Respondent's files do not indicate that the letter was returned
to respondent undelivered.
On November 3, 1995, respondent mailed two separate notices
of deficiency2 to petitioner determining deficiencies in and an
addition to his Federal income taxes for the taxable years 1990,
1991, 1992, and 1993 as follows:
2 One of the notices includes the determination for 1990, and
the other notice includes the determination for 1991, 1992, and
1993.
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Last modified: May 25, 2011