Gustavo and Maria Guerrero - Page 3

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          that their tax return for 1993 had been selected for                        
          examination.  On October 4, 1996, respondent sent a so-called               
          30-day letter to petitioners at the Los Angeles address                     
          providing petitioners with notice of respondent's proposed                  
          changes to their tax liability for 1993.  Respondent did not                
          receive either of the above-described letters back from the U.S.            
          Postal Service undelivered.                                                 
               On or about September 27, 1996, petitioners wrote to the               
          Internal Revenue Service Center in Fresno, California,                      
          requesting a copy of their 1993 tax return.  Although                       
          petitioners' September 27, 1996, letter is not part of the                  
          record in this case, it appears that petitioners listed their               
          address as 10426 Adella Ave., Southgate, California 90280 (the              
          Southgate address).  On December 31, 1996, the operations                   
          manager for the Document Services Branch at the Internal Revenue            
          Service Center, Western Region, mailed a letter to petitioners              
          at the Southgate address seeking additional information                     
          regarding petitioners' request for a copy of their 1993 tax                 
          return.                                                                     
               In the meantime, one day earlier, on December 30, 1996,                
          respondent had mailed a joint notice of deficiency to                       
          petitioners at the Los Angeles address determining a deficiency             
          in their Federal income tax for 1993 in the amount of $18,339               
          and an accuracy-related penalty in the amount of $3,668 pursuant            





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