- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011