- 3 - Respondent's notice of deficiency is dated April 13, 1984. The petition in this case was filed on April 18, 1995, that is, 4,032 days, or approximately 11 years, after the mailing of the notice of deficiency. Petitioner resided in Peoria, Arizona, when her petition was filed. Petitioner filed an amended petition pertaining to those same years (1979 through 1981) on June 26, 1995. Respondent's notice of deficiency was sent to petitioner by certified mail addressed as follows: Donna Clevenger, 20935 Bell Avenue, Lakeview, California 92353 (hereafter the Bell Avenue address). Respondent asserts that this address was on petitioner's last filed tax return. The property located at the Bell Avenue address consisted of a mobile home that was owned by petitioner and her husband and was situated on 2-1/2 acres of land. Petitioner resided with her husband, Coy A. Clevenger, at all times at issue and until his death in 1992. Petitioner's last filed return prior to the issuance of the statutory notice of deficiency was the 1978 return filed jointly with her husband on February 2, 1983. Petitioner did not file a Federal income tax return either individually or jointly with her husband for the taxable years 1979, 1980, and 1981. At respondent's request, the Fresno Service Center, the service center with which petitioner was required to file her Federal income tax returns during the years at issue, conducted a diligent search of itsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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