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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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