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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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