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petitioners at HC 71 Lone Pine Creek Road, Burns, OR 97720; the
other was addressed to them at HC 71 Lone Pine Road, Burns, OR
97720.2
The post office in Burns, Oregon, received the envelopes
containing the notices of deficiency. On May 9, 1996, the Postal
Service delivered notification forms to petitioners at the
address designated on the envelopes, stating that certified mail
from the IRS was being held and could be signed for and picked up
at the local post office. After 5 days, a second set of such
notices was delivered. Neither notice of deficiency was picked
up or received by petitioners. Each notice of deficiency was
returned to respondent on or about May 29, 1996. The envelopes
containing the notices were stamped "Unclaimed" by the U.S.
Postal Service. The originals and copies of the notices of
deficiency that were mailed to petitioners on May 3, 1996, were
placed in petitioners' administrative file, along with the
envelopes in which they had been mailed.
On their Federal income tax return for the period beginning
on October 1, 1993, and ending September 30, 1994, which was
received by respondent on June 27, 1995, petitioners listed their
address as HC 71 Lone Pine Creek Road, Burns, OR 97720. They
2According to the testimony of the postmaster for Burns,
Oregon, any envelope addressed to Burns, Oregon, bearing the name
Hoyt and HC 71 would have been delivered to the proper mailbox.
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