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20134 Leadwell St., #222, Winetka, CA 91306 (the Winetka
address).
On July 18, 1996, respondent sent, by certified mail, a
notice of deficiency to petitioners for taxable year 1993,
determining a deficiency in the amount of $5,227. That notice of
deficiency was mailed to petitioners at the Studio City address.
Subsequently, on December 6, 1996, respondent mailed, by
certified mail, a notice of deficiency for taxable year 1994,
determining a deficiency of $10,732 and a section 6662(a) penalty
of $2,146. Like the 1993 notice of deficiency, the 1994 notice
of deficiency was sent to petitioners at the Studio City address.
The petition herein was filed on January 27, 1997, timely with
regard to the 1994 notice of deficiency but 103 days after the
mailing of the 1993 notice of deficiency.
At the hearing in this matter, petitioner testified that
petitioners moved from the Studio City apartment to the Winetka
address (which is the address set forth on the petition) on or
about July 1, 1996. He stated that they did have a forwarding
order on record with the post office. He also testified as to a
rather unusual mail distribution scheme at the Studio City
apartment complex.
According to petitioner, the manager of the Studio City
apartment complex went to the post office and picked up the mail
for the complex. She then would return to the complex to
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