Donna C. Clevenger - Page 12

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          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 Internal              




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