Walter J. Hoyt, III and Betty J. Hoyt - Page 6

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          was mailed to an address that is identical to the address                   
          petitioners listed on the Federal income tax return they filed              
          most recently before the mailing of the notices of deficiency.              
          The other notice of deficiency was mailed to petitioners at a               
          similar address except the word "Creek" was omitted.  Petitioners           
          never provided clear and concise notice to respondent that they             
          wanted to be contacted at a different address.  During cross-               
          examination, petitioner testified as follows:                               

               Q.  Okay. Have you ever sent the Internal Revenue                      
               Service a notice or requested in any way that they not                 
               send notices of deficiency related to your personal tax                
               situation?  Have you ever requested they send those                    
               notices to any address other than HC 71 Lone Pine Road,                
               Burns, Oregon, 97720?                                                  
               A.  I've never requested they send them to any address                 
               so the answer is no.                                                   

               We are further satisfied that at least one of the notices of           
          deficiency was addressed to petitioners at their last known                 
          address (according to the testimony of the U.S. Postal Service              
          employee, both addresses were proper).  See King v. Commissioner,           
          857 F.2d 676 (9th Cir. 1988), affg. 88 T.C. 1042 (1987); Abeles             
          v. Commissioner, 91 T.C. 1019, 1035 (1988).                                 
               Petitioners argue that respondent was aware of numerous                
          other addresses used by petitioner as a tax matters partner in              
          various partnerships.  According to petitioners, any of these               
          other addresses should be considered their last known address               





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