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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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