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Address Used for Mail: We consider how petitioners reported
their address on tax forms. Friedman v. Commissioner, T.C. Memo.
1982-178. Petitioners’ 1988 Forms W-2 went to Mary Street, and
their 1989 and 1990 Forms W-2 were mailed to the Alessandro
office. For 1988 and 1989, their Forms 1099 went to Mary Street.
While some documents4 listed 20 The Point as petitioner's
address, numerous documents dated after August 31, 1988, listed
Mary Street as petitioners' address. These included petitioners'
investment statements from Paine Webber, Prudential Securities,
and PGF Securities. In reaching petitioners, the administrator
for petitioner's pension plan and petitioners' accountant
McKenzie used the Mary Street address. Further, on agreements
regarding 15 Sandpiper, petitioners listed Mary Street as their
address.
At trial, Terry testified that he "felt more secure about
having their mail delivered at [the] 2320 Mary Street property
than at 20 The Point." According to petitioners, the caretaker
at Mary Street would receive the mail daily and place it in the
garage. Then, periodically, petitioners would pick up the mail.
Further, on brief, petitioners state that they "did not want to
burden themselves with having to change all of their records to
4 20 The Point was listed as petitioners' address on a
letter to Security Pacific National Bank, a San Diego Country
Club Membership Application, a Fire Insurance Exchange
Declaration, and Pacific Bell statements.
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