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tax return Classen address; (3) he had not received any notices
regarding the assessment of additional taxes; (4) he had advised
respondent previously that his mailing address should be the P.O.
drawer address; and (5) respondent was aware that "There had been
some difficulty in receiving certified mail at" the tax return
Classen address.
Petitioner's October 23, 1990, letter was received by
respondent on October 25, 1990. An "en mod" search4 was made on
November 2, 1990, at 10:09 a.m. The first page of the report on
the en mod search shows the I.R.S. Classen address; the second
page does not show any address; the third page shows the P.O.
drawer address and another address, as follows: 124 E. MAIN
NORMAN OK 73069 (hereinafter sometimes referred to as the E. Main
address). Petitioner maintained a law office at the E. Main
address from about 1982 through about 1984. (In or about 1984,
petitioner moved his law practice to Tulsa from the E. Main
address, in Norman. After about a year, he moved his law
practice back to Norman.)
On or about November 7, 1990, petitioner's October 23, 1990,
letter was referred to Janine MacKenzie, hereinafter sometimes
referred to as MacKenzie. An "amdissa", dated November 2, 1990,
10:41 a.m., was attached to petitioner's October 23, 1990,
letter, and indicates that a notice of deficiency had been sent
4An "en mod" search is an I.R.S. search through I.R.S.
records for a taxpayer's most recently known address.
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