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Sometime before March 19, 1996, petitioners submitted to the
service center a Form 8821, Tax Information Authorization,
regarding taxable years 1988 through 1994. The form listed
petitioners' address as the Grand Avenue address. By letter
dated March 19, 1996, that form was returned to petitioners
because it did not properly contain both petitioners’ signatures
and signature dates.
Petitioner Sherelle D. Brooks-Johnson (Ms. Brooks-Johnson)
testified at the hearing in this matter. While Mr. Johnson was
present in the courtroom and was invited by the Court to testify,
he declined. Ms. Brooks-Johnson stated that petitioners had
lived at the Scenic Ridge address until March 1995, at which time
they moved to the Grand Avenue address. The Diamond Bar address
was a second address that they used for business. She further
stated that the audit of the 1993 return was ongoing at that time
and that she had given her new address to the examining agent.
Examination of the 1994 return was conducted by a different
agent, but Ms. Brooks-Johnson stated that both agents were aware
of the two audits. Neither of those agents was called as a
witness. The record is not clear as to whether or when such
notice of change of address was given to the agent examining
1993, and petitioners did not have any correspondence from him or
her before September 3, 1996.
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Last modified: May 25, 2011