- 2 -
file their petition for 1993 within the time period prescribed by
section 6213(a).
Background
Justice James Onah (petitioner) and Mrs. Onah filed a joint
1995 Federal income tax return, Form 1040, with the Internal
Revenue Service at Fresno, California, on April 24, 1996.
Petitioners set forth therein that their address was 11684
Ventura Blvd., Apt. 348, Studio City, CA 91604 (the Studio City
address). On May 30, 1996, respondent mailed to petitioners a
letter advising them that their 1994 Federal income tax return
was selected for examination and requesting that they contact
“the person named above” within 10 days to arrange an
appointment. The May 30, 1996, letter was addressed to
petitioners at 21405 Devonshire St., Suite 213, Chatsworth, CA
91311-2940 (the Chatsworth address).
Petitioner mailed a letter dated July 9, 1996, addressed to
“IRS, 300 N. Los Angeles St., Los Angeles, Ca 90001" in which he
made reference to a letter dated May 19, 1996. The record does
not reflect any letter dated May 19, 1996. Petitioner’s July 9,
1996, letter contains the statement “We are responding beyond the
10 days stated in your letter because we did not receive your
request in time as it was sent to our previous address and
therefore delayed getting to us.” The letter dated July 9, 1996,
contains in the upper right hand corner the following address:
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011