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"Statement of Affairs of Debtor Not Engaged in Business", dated
and executed on February 10, 1984, in which petitioner and her
husband stated that they resided at the Bell Avenue address from
1978 until June 1983. On February 10, 1984, petitioner and her
husband also executed a "Statement of Compensation Paid For
Assistance in Connection with the Filing of the Bankruptcy Case
Pursuant to Local Bankruptcy Rule 221", promptly thereafter filed
with the bankruptcy court. This statement identified the Bell
Avenue address as real property owned by petitioner and her
husband as of the date of the filing of the bankruptcy petition,
and as property exempt pursuant to 11 U.S.C. sec. 522(d)(1)
(Supp. II, 1978), as the residence of the debtor or a dependent
of the debtor. Petitioner and her husband were discharged from
bankruptcy on June 29, 1984.
On November 2, 1989, petitioner wrote to the Internal
Revenue Service Problem Resolution Office in Laguna Nigel,
California, and requested audit reports. In response, on January
17, 1990, personnel of that office sent petitioner copies of her
audit reports for the taxable years 1979, 1980, and 1981. A copy
of the original notice of deficiency dated April 13, 1984, was
included with the audit reports received by petitioner.
Ernest Avilla (Avilla) worked as the postmaster for the post
office in Nuevo, California (hereafter the Nuevo post office),
from 1981 through 1984. His job functions as postmaster included
traveling to the Lakeview post office approximately once a week
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