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records and determined that the original as well as any copies of
any joint income tax returns (Form 1040) filed by petitioner for
the years prior to and including the 1978 taxable year had been
routinely destroyed by respondent after a 7-year retention
period. Petitioner did not produce a copy of her 1978 joint
income tax return at trial. There is no evidence in the record
that the notice of deficiency ever was returned to respondent as
undeliverable.
Petitioner claims that at the time of the issuance of the
notice of deficiency in April 1984, her last known address, to
which the notice of deficiency should have been sent, was "30840
Apricot Avenue, Nuevo, California" (hereafter the Apricot
address). According to petitioner, she and her husband moved
from the Bell Avenue address to the Apricot address in mid-
January 1983, and therefore the Apricot address would have been
the address on her 1978 joint income tax return. Petitioner
testified that the property located at the Apricot address was a
horse ranch known as Solar View Farms owned by Rick Fritz.
Petitioner claims that she and her husband lived in a house on
the property in exchange for taking care of the ranch and the
horses. Mr. Fritz did not testify at the hearing.
On February 13, 1984, petitioner and her husband filed a
voluntary petition in bankruptcy with the U.S. Bankruptcy Court
for the Central District of California. On March 6, 1984,
petitioner and her husband filed with the bankruptcy court a
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