Donna C. Clevenger - Page 4

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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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