- 3 - At the time the notice of deficiency was mailed, petitioner was living at 14767 Delano Street #204, Van Nuys, California (Van Nuys address). It is unclear from the record when petitioner moved to this address. Petitioner actually received a copy of the notice of deficiency in late April 1996. A friend of petitioner who was residing at the 720 Concord Street address received the notice of deficiency mailed to that address and gave it to petitioner in late April 1996. Ninety days from the date the notice was mailed was July 8, 1996. The petition was dated June 19, 1996; however, it was not mailed until July 9, 1996, 91 days after the notice was mailed to petitioner, and was filed on July 12, 1996. Petitioner did not file tax returns for taxable year 1989 through 1995. Respondent became aware of a change of address for petitioner in mid-1992, before petitioner had moved to the Van Nuys address. In 1997, petitioner filed a tax return for the 1996 taxable year which updated petitioner's address in respondent's computer files and deleted the address notification received by respondent in 1992. Petitioner was arrested on Federal money-laundering charges in 1991 and convicted in 1993. Following his arrest, petitioner was required to report any changes of address to the office of pretrial services of the U.S. District Court for the Central District of California. Petitioner's reporting requirement was in effect in April 1996. Sometime before April 9, 1996, the date that the notice of deficiency was mailed, petitioner notified thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011