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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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