- 12 - against petitioner and her husband for the 1978 tax year. The lien identifies petitioner's residence as the Bell Avenue address. Respondent argues that because this lien was filed based upon petitioner's last filed income tax return, an inference can be made that respondent used petitioner's last filed return to determine petitioner's address when filing this lien. We conclude on the basis of the substantial available evidence that the Bell Avenue address was the address listed on petitioner's 1978 tax return and was petitioner's residence address in February 1983 when she and her husband filed their return for 1978. Petitioner never sent notice to respondent specifically informing respondent that the address on her most recent return no longer should be used or that she wanted a different address to be used for tax purposes. Based upon all the evidence in the record, we find that respondent mailed the subject notice of deficiency to the address which was shown as petitioner's residence on her most recent return prior to the date of the deficiency notice and which was in fact her residence at the time of filing that return. Petitioner argues that respondent knew that her address had changed since her most recent return. She contends that respondent knew of her address change by virtue of her bankruptcy petition and a Form 3242 "Request for Information From Employer (To Locate Individual)", which had been mailed by the InternalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011