Walter J. Hoyt, III and Betty J. Hoyt - Page 4

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          listed the same address on their 1994 Federal income tax return,            
          which was received by respondent on June 11, 1996.                          
               Petitioner served as the tax matters partner in numerous               
          partnerships.  As such, he was sent numerous FPAA's, many of                
          which were prepared by Mr. Pierce.  During the period from March            
          25 through May 3, 1996, respondent sent by certified mail at                
          least 10 FPAA's to petitioner in his capacity as a tax matters              
          partner.  The FPAA's were addressed to petitioner at various                
          locations and were either claimed or unclaimed and returned to              
          respondent.                                                                 

                                       OPINION                                        

               We first address petitioners' suggestion that a notice of              
          deficiency for the year 1987 was not issued or sent by certified            
          mail to them on May 3, 1996.  Petitioners point out that they, or           
          individuals acting on their behalf, were almost on a daily basis            
          claiming numerous letters mailed to them by respondent during               
          that period.  As petitioners view the situation, the fact that              
          neither notice of deficiency was claimed raises questions of                
          whether those notices were actually issued and mailed.                      
          Petitioners maintain that they had no reason not to claim any               
          notice of deficiency that might have been issued and mailed to              
          them in May 1996.  According to petitioners, if a notice of                 







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