Anthony Sicari and Esther Sicari - Page 3

                                        - 3 -                                         
          respondent determined deficiencies in and additions to                      
          petitioners' Federal income taxes as follows:                               
                  Additions to Tax                                                    
       Sec.       Sec.      Sec.      Sec.                Sec.                        
  Year Deficiency 6653(a)(1) 6653(a)(2)  6661     6653(a)(1)(A)    6653(a)(1)(B)      
  1983  $99,613    $4,981        1     $24,903       --              --               
  1984   38,967      1,948        1       9,742      --             --                
  1985   30,124      1,506        1       7,531      --             --                
  1986   42,014        --        --      10,503.50     $2,101                  1      
  1  50 percent of the interest due on the deficiencies.                              
               On November 10, 1992, the notice of deficiency was returned            
          to the Examination Support and Processing unit of the Albany                
          District Office.  The envelope bore a "Return to Sender" stamp-             
          mark in red ink, and the "REASON CHECKED" for return was                    
          "Unclaimed".1  Also, the words "Return unclaimed" had been                  
          handwritten at the top of the envelope by Marianne Walker                   
          (Walker), the Postmaster for Gardiner, New York.  Another stamp-            
          mark on the envelope listed "Name", "1st Notice", "2d Notice",              
          and "Return".  The dates "9-24", "10-16", and "10-19" had been              
          handwritten next to "1st Notice", "2nd Notice" and "Return",                
          respectively.                                                               
               Petitioners have resided in the same house in Gardiner, New            
          York, since approximately 1976.  In each of the years 1991 and              


          1    "Unclaimed" was one of the options listed on the envelope as           
          available to explain why the letter was being "Returned to                  
          Sender".  The other options were:  "Refused"; "Attempted-Not                
          Known"; "Insufficient Address"; "No such street [or] number"; "No           
          such office in state"; and "Do not remail in this envelope".                
          None of these other options had been checked off.                           




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011