- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011