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In a subsequent document filed with the Court, petitioner
admitted that he was living at the Atteiram Drive address on June
11, 1993, but that he did not receive any notice of deficiency at
that address. Petitioner stated further that he had moved from
the East 11th Street address in 1989 and that his last known
address was "114 Nourcross Way, Rome, Georgia".4
This matter was called for hearing at the Court's motions
session in Washington, D.C., on April 8, 1998. Counsel for
respondent appeared at the hearing and presented argument and
exhibits in support of the pending motion.
Petitioner did not appear at the hearing on April 8, 1998.
However, he did file a Rule 50(c) statement, attached to which
were "some copies of my tax." These documents include copies of:
Purported Federal and State corporate income tax returns for
petitioner's company Millsap Construction for 1990, purported
Federal and State income tax returns for petitioner and Mrs.
Millsap for 1990 (see supra note 2), the Federal income tax
return for petitioner and Mrs. Millsap for 1991 (see supra p. 4),
4 The 1994 edition of Publication 65, the National Five-
Digit ZIP Code and Post Office Directory, published by the U.S.
Postal Service does not list any "Nourcross Way" in Rome,
Georgia. There is, however, a "Norcross Way" in Rome, Georgia
30165. We note that documents pertaining to the 1989 taxable
year that were attached to petitioner's Rule 50(c) statement,
viz, Forms 1099-MISC purportedly issued by Millsap Construction,
repeatedly reference "114 N. Crossway St., Rome, GA 30161". The
ZIP Code directory does not list "N. Crossway" or "Crossway" in
Rome, Georgia.
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