Nemat Mostaan - Page 6

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          April 1994 and that he notified respondent of this change of                
          address.                                                                    
          Petitioner claims that he was aware of audit activity with                  
          respect to his taxes for the years in issue and later received a            
          so-called 30-day letter concerning the possibility of an Appeals            
          Office conference.  He claims that he called respondent's offices           
          at least six times between May 18 and June 20, 1995, that he                
          spoke with IRS personnel by telephone several times during that             
          period, and that during those telephone conversations he notified           
          respondent's representatives of his change of address.                      
          Petitioner presented a chart describing the time and subject                
          matter of the alleged telephone conversations.  Petitioner                  
          prepared the chart himself.  He attached to it a                            
          telecommunications expense report, allegedly from the records of            
          his employer, to demonstrate that several of the calls had been             
          made.  Respondent disputed the authenticity of the report and the           
          accuracy of the chart.  Petitioner failed to present any                    
          substantiating witnesses or other evidence.  Petitioner failed to           
          establish notice of change of address as a result of the alleged            
          telephone conversations.                                                    
          Petitioner offered in evidence a series of letters dated                    
          between April 12, 1994, and February 9, 1995, addressed to IRS              
          personnel and bearing the return address of 13 Skylark Drive.  In           
          several of these documents, petitioner purports to advise                   
          respondent of his change of address.  Respondent asserts that she           




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