Donna C. Clevenger - Page 3

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               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 its               




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