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Petitioner contends that the notice of deficiency was not mailed
to his last known address pursuant to section 6212(b) and that
the 90-day filing period should not begin to run until he
received actual notice.
Respondent determined deficiencies in petitioner's Federal
income taxes and additions to tax as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1989 $24,015 $5,325 $1,421
1990 1,620,549 404,870 106,623
Background
At the time the petition in this case was filed, petitioner
resided in Van Nuys, California.
The notice of deficiency was mailed on April 9, 1996.
Respondent mailed copies of the notice of deficiency to
petitioner at each of the following seven addresses: (1) 5030
West 131st Street, Hawthorne, California 90250-5021; (2) 117 24th
Street, Manhattan Beach, California 90266; (3) 708 Concord
Street, Glendale, California 91202; (4) 720 Concord Street,
Glendale, California 91202; (5) 1500 Turks Head Building,
Providence, Rhode Island 02903; (6) 311� Winnepeg Place, Long
Beach, California 90814-2564; and (7) c/o Patricia Masino, 311�
Winnepeg Place, Long Beach, California 90814-2564. Petitioner
has lived at five of these addresses.
1(...continued)
effect for the years at issue.
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