James A. and Muriel M. Andrews - Page 3

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          The U.S. Postal Service does not deliver mail to petitioners at              
          their residence; instead, petitioners obtain their mail from P.O.            
          Box 227 at the Peconic, New York, branch of the U.S. Postal                  
          Service.  However, mail addressed to them at 772 Indian Neck                 
          Lane, Peconic, New York, is put into P.O. Box 227.                           
               On April 2, 1996, respondent mailed a notice of deficiency              
          with respect to petitioners’ 1992 taxable year to them by                    
          certified mail at the Box 227 address.3  The address on                      
          petitioners’ 1992 and 1993 tax returns was the Box 227 address.              
          The address on their timely filed 1994 return, the last return               
          they filed before the notice of deficiency was mailed, was as                
          follows:  772 Indian Neck Lane, P.O. Box 227, Peconic, New York              
          11958.  In January and February 1996, petitioners received                   
          certified mail from the IRS at the Box 227 address.  Petitioners             
          failed to include an address on their 1995 return, which was                 
          filed on or about April 12, 1996.                                            
               In February 1996, petitioner and petitioners’ accountant,               
          Cyril Bezkorowajny, met with a revenue agent with respect to an              
          examination he was conducting of an employee benefit plan in                 
          which petitioner participated.  From that time on, petitioner and            
          Mr. Bezkorowajny were aware that it was likely that petitioners              
          would be receiving a notice of deficiency with respect to the                

               3 The notice was dated Apr. 3, 1996, but was actually mailed            
          on Apr. 2.                                                                   

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