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petitioner at 165 N. Fayette Dr., Fayetteville, Georgia 30214
(the Fayetteville address). The Fayetteville address is the
address listed on petitioner's 1987 tax return which is the last
return that petitioner filed prior to the mailing of the notice
of deficiency for 1990.
The notice of deficiency for 1990 was returned to respondent
undelivered, marked "Unclaimed", and listing a forwarding address
for petitioner of 2370 Ambassador Drive, Lithia Springs, Georgia
30057 (the Lithia Springs address)
On June 22, 1993, respondent mailed a notice of deficiency
to petitioner determining deficiencies in and additions to his
Federal income taxes for 1988 and 1989. Respondent mailed the
notice of deficiency to petitioner at the Fayetteville address.
On September 14, 1993, petitioner filed a timely petition for
redetermination with the Court (assigned docket No. 20017-93)
respecting the notice of deficiency for 1988 and 1989, listing
his address as the Lithia Springs address.
In January 1995, petitioner met with Revenue Officer Sharon
Pittman to discuss a levy that had been placed against his bank
account for taxes allegedly due for 1990. Petitioner advised
Revenue Officer Pittman that he was residing at the Lithia
2(...continued)
the facts and circumstances, we conclude that the notice of
deficiency for 1990 was mailed on Feb. 16, 1993.
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