Patrick Anthony Masino - Page 3

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                  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 the                           


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