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1985 Nov. 30,1987
1986 Jan. 19,1988
On each of these tax returns, petitioner showed his address
as "1602 Classen, NORMAN, OK 73069", hereinafter sometimes
referred to as the tax return Classen address.
The June 18, 1987, discharge order in petitioner's 1987
bankruptcy proceeding, was issued before petitioner filed any of
his tax returns for the years in issue. In this discharge order,
petitioner's address is shown as Post Office Drawer B, Norman,
Oklahoma 73070, hereinafter sometimes referred to as the P.O.
drawer address. One of the creditors listed in the discharge
order is "Internal Revenue Service, Austin, Texas 73301".
Revenue agent John Robert Burns (hereinafter sometimes,
referred to as Burns) first interviewed petitioner on June 13,
1989, more than 1 year after petitioner filed the tax returns.
Before this first interview, respondent had sent a letter to
petitioner. By this time, the address respondent was using for
petitioner was "1602 CLASSEN, NORMAN OK 73071-4616", hereinafter
sometimes referred to as the I.R.S. Classen address.
Petitioner came to a second meeting in Burns' office on
October 31, 1989. On January 25 and May 9, 1990, Burns sent to
petitioner letters enclosing Forms 872, to extend the period for
limitations; the May 9 letter was sent by certified mail.
Petitioner did not respond to these letters. In May or June 1990
petitioner's case was reassigned from Burns to another revenue
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