- 12 - circumstances of each case. Alta Sierra Vista, Inc. v. Commissioner, supra at 374. Petitioners' amended return for 1986 was the most recent return filed by petitioners when the notice of deficiency was issued on October 9, 1992. Respondent received that amended return on May 14, 1991. On that return, petitioners listed their address as the Route 208 address, consistent with their 1986 Form 1040. Petitioners did not file their 1991 return until 1995. The record does not contain copies of petitioners' 1987, 1988, 1989, or 1990 returns, and petitioners do not contend that those returns listed an address other than the Route 208 address. Printouts of the searches conducted on respondent's INOLE and ENMOD computer databases, dated August 21, 1992, and October 1, 1992, indicate that petitioners listed their address as the Route 208 address on their 1988 and 1989 returns. On this record, we find that respondent mailed the subject notice of deficiency to the address shown on petitioners' most recent return.4 Petitioners argue that respondent knew that their address had changed since their most recent return. Although petitioners admitted at trial that they did not notify respondent 4 The record does not disclose whether petitioners' 1986 amended return had been properly processed by the Albany District Office so that the address appearing on that return was available to respondent's agent who prepared the subject notice prior to its mailing. As noted, however, respondent's computer records reflect that petitioners listed the Route 208 address on their 1988 and 1989 returns, and petitioners do not claim to have listed a different address on their 1990 return.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