Terry Duane Beall and Joyce Engel Beall - Page 20

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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             
               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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