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though the letter was mailed to their Riva Ridge address. After
receiving the letter, petitioners did not inform Revenue Agent
Myers of their move to the Merritt Island address. Petitioners
did however, file a change of address form with the U.S. Postal
Service for their move from the Riva Ridge address to the Merritt
Island address.
Revenue Agent Myers, in his examination of petitioners'
Federal income tax returns, relied primarily on financial
records, depositions, and other information held by the Resolu-
tion Trust Corp. (RTC), which was involved in a bankruptcy
proceeding commenced by petitioners in Houston, Texas, in 1989.
Revenue Agent Myers learned of petitioners' move to Merritt
Island in the summer of 1991 from Mary Wilson, an attorney with
RTC.
In April 1992, Christa Morgan (Revenue Agent Morgan), a
revenue agent in Florida, began an income tax examination of
Classified Property Management Corp. (CPMC), a corporation with
which petitioners were associated. Revenue Agent Myers contacted
Revenue Agent Morgan to coordinate the individual and corporate
audits. In early May 1992, petitioner told Revenue Agent Morgan
that, on May 13, 1992, he and his wife were moving to 6591 Bayou
Glen in Houston, Texas (the Bayou Glen address). Revenue Agent
Morgan informed Revenue Agent Myers of petitioners' move to the
Bayou Glen address.
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