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agent, Pat Merideth, hereinafter sometimes referred to as
Merideth. On June 21 and July 3, 1990, Karen Spencer
(hereinafter sometimes referred to as Spencer), a supervisor,
telephoned petitioner's office but did not speak with him. On
July 9, 1990, Merideth telephoned petitioner and discussed with
him a possible extension of the limitations period. On July 30,
1990, Spencer telephoned petitioner and verified that the I.R.S.
Classen address was petitioner's mailing address.
A 30-day letter was prepared, dated August 23, 1990, using
the I.R.S. Classen address. Spencer approved the 30-day letter
on August 24, 1990. It is not clear from the record whether the
30-day letter was sent to petitioner.
On September 14, 1990, the notice of deficiency for 1982
through 1986 was sent by certified mail to petitioner at the
I.R.S. Classen address. The U.S. Postal Service noted on the
notice of deficiency envelope the following: "2nd Notice 9-20",
"Return 9-30", "RETURNED TO WRITER * * * Unclaimed X". The
notice of deficiency was returned to, and was received by,
respondent on October 5, 1990.
On October 23, 1990, petitioner sent a letter to respondent
stating as follows: (1) He was advised, on or about August 24,
1990, that respondent intended to assess additional taxes against
him for 1982 through 1986; (2) he formally demanded that all
"assessment notices" be mailed to him by ordinary and by
certified mail to two addresses--the P.O. drawer address and the
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