- 3 -
At the time the petition was filed, petitioners resided in
Houston, Texas. Petitioners were husband and wife during the
taxable years 1987, 1988, and 1989. Petitioners filed their
original Federal joint income tax return for 1987 on March 26,
1990, their original Federal joint income tax return for 1988 on
June 4, 1990, and their original Federal joint income tax return
for 1989 on June 28, 1990. All three returns listed petitioners'
address as 3205 Riva Ridge in Austin, Texas (the Riva Ridge
address). Petitioners also filed an amended U.S. individual
income tax return (Form 1040X), for the tax year 1987 on June 20,
1991. On the Form 1040X, petitioners also listed the Riva Ridge
address as their home address. Petitioners resided at the Riva
Ridge address until June 6, 1991, when they moved to 4080
Savannahs Trail in Merritt Island, Florida (the Merritt Island
address).
In March 1991, Revenue Agent Alan Myers (Revenue Agent
Myers) was assigned to audit petitioners' 1987 and 1988 Federal
income tax returns. On or about July 15, 1991, Revenue Agent
Myers mailed a letter to petitioners at the Riva Ridge address
informing them that their 1987 and 1988 Federal income tax
returns had been placed under examination. The July 15, 1991,
letter included Revenue Agent Myers' telephone number and mailing
address, and it requested that petitioners contact Revenue Agent
Myers if they had any questions. The July 15, 1991, letter was
received by petitioners at their Merritt Island address even
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011