- 3 - 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 pursuantPage: Previous 1 2 3 4 5 6 7 8 Next
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