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respondent or the U.S. Postal Service indicate that a notice of
deficiency for the year 1992 was sent by certified mail to
petitioners on October 2, 1996.
During the relevant period, petitioner's father served as a
tax matters partner in a number of partnerships that he
(petitioner's father) promoted. Petitioner was employed by his
father in connection with some of the partnerships and was a
partner in some of them as well. As a result, petitioner had
previously seen "volumes" of notices of final partnership
administrative adjustment (FPAA) but only a "handful" of notices
of deficiency. Petitioner considers a notice of deficiency and
an FPAA to be "basically the same".
OPINION
Having determined a deficiency in petitioners' 1992 Federal
income tax, respondent was authorized to notify petitioners of
such by certified mail. Sec. 6212(a). A review of the records
that are typically generated when a notice of deficiency is
prepared and mailed to a taxpayer indicates that a notice of
deficiency for the year 1992 was issued and mailed to petitioners
on October 2, 1996. The records are consistent with the
recollection of Mr. Pierce, the IRS employee who actually
prepared the notice of deficiency and supervised its mailing,
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