- 7 - On or about November 20, 1995, respondent's service center in Austin, Texas (the Austin service center) sent a 30-day letter to petitioner (the 30-day letter). The 30-day letter stated that respondent had no record of receiving an income tax return from petitioner for the taxable year 1993. The 30-day letter then proposed a deficiency in petitioner's income tax and additions to tax for 1993 based on income reported to respondent by third parties. Such income included discharge-of-indebtedness income in the amount of $1,004,812, i.e., the sum of the amounts appearing on the information returns as set forth above.4 The 30-day letter stated that petitioner could appeal "the proposed assessment" to the IRS Appeals Office. The 30-day letter was mailed to petitioner at her former address in Albuquerque, New Mexico (the Albuquerque address).5 The Albuquerque address was petitioner's address as it appeared in respondent's computer records at the time that the 30-day letter was sent (i.e., on or about November 20, 1995). Prior thereto, on October 23, 1995, petitioner filed a Federal income tax return for the taxable year 1994. Petitioner listed her address on her 1994 return as P.O. Box 405, Hobbs, New Mexico 4 The proposed deficiency was also based on $5,003 of unreported interest, dividends, and gain from the sale of securities. A single individual having only such amount of income in 1993 was not required to file an income tax return for that year. Sec. 6012(a)(1). 5 Petitioner moved from the Albuquerque address in June 1993.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011