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Addition to Tax
Year Deficiency Sec. 6651(a)(1)
1990 $4,107 ---
1991 7,233 ---
1992 4,790 $832
1993 3,232 ---
The notices of deficiency were mailed to petitioner in a single
envelope addressed to petitioner at the Wilmington address as
listed in petitioner's 1994 tax return--the last return filed by
petitioner prior to the mailing of the above-described notices of
deficiency.
Petitioner concedes that he did not provide respondent with
notice of his change of address to the Lewiston address between
the time that he filed his 1994 tax return and the date that
respondent mailed the above-described notices of deficiency.
On February 23, 1996, the envelope bearing the notices of
deficiency was returned to respondent undelivered and marked "BOX
CLOSED UNABLE TO FORWARD RETURN TO SENDER". There is no
explanation in the record why it took the U.S. Postal Service
over 3 months to return to respondent the envelope bearing the
undelivered notices of deficiency. In any event, upon receipt of
the undelivered notices of deficiency, respondent's agents
conducted a computer search in an effort to obtain petitioner's
correct address. As a result of that search, and relying upon
information reported to respondent by third parties on Forms 1099
and W-2, respondent mailed copies of the notices of deficiency to
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