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upon closing her records because she had not received any
notification from the taxpayers that they had moved.
On March 22, 1993, a statutory notice of deficiency for the
tax years 1987 and 1988 was mailed by certified mail to peti-
tioners at the Bayou Glen address. On June 24, 1993, a notice of
deficiency for the 1989 taxable year was mailed by certified mail
to petitioners at the Bayou Glen address. At the time of mailing
of both notices of deficiency, the Internal Revenue Service
personnel involved in the preparation and mailing of the notices
did not know of petitioners' Brownway address.
Mr. Mladenka, the mail carrier at the Richhill Post Office
who delivered the mail at the Bayou Glen address, crossed out the
Bayou Glen address on both notices of deficiency and handwrote
petitioners' Brownway address on the face of both notices of
deficiency. Mr. Mladenka then forwarded the notices of
deficiency to the Julius Melcher Post Office for delivery to the
Brownway address.
On March 25, 1993, Mr. Jared Horton, a mail carrier at the
Julius Melcher Post Office, attempted to deliver the March 22,
1993, notice of deficiency to petitioners at the Brownway
address; however, after he rang the doorbell twice, nobody
answered the door. Mr. Horton then placed a Form 3849 (yellow
slip) in petitioners' mailbox at the Brownway address. The
yellow slip informed petitioners that the Postal Service was
holding a certified letter for them and that the petitioners
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