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The issue for decision is whether a notice of deficiency was
issued and properly mailed to petitioners for the year 1992.
According to respondent, on October 2, 1996, a notice of
deficiency in which a deficiency, additions to tax, and a penalty
with respect to petitioners' 1992 Federal income tax were
determined was issued and sent to petitioners by certified mail.
Petitioners admit that a document sent by respondent by certified
mail was received in October 1996 but they claim that the
document was not a notice of deficiency. According to
petitioners, the document was a statement of income tax changes
that they had previously received from the revenue agent
conducting the examination of their 1992 year.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners were husband and wife during 1992. They filed a
timely joint Federal income tax return for the year 1992 on or
about October 15, 1993. References to petitioner are to Walter
J. Hoyt IV. Petitioners resided in Willows, California, at the
time their 1992 return was filed and continued to reside there at
least until the petition was filed in this case. The parties
have stipulated, and we find as a fact, that for purposes of
section 6212, petitioners' last known address as of October 2,
1996, was P.O. Box 642, Willows, California 95988.
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