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