- 3 -
On October 1, 1993, respondent sent petitioner a notice of
deficiency for the taxable year 1991 (the notice of deficiency
for 1991). In the notice of deficiency for 1991, respondent
determined the following deficiency in petitioner's Federal
income tax and addition to tax:
Addition to Tax
Year Deficiency Sec. 6651(a)
1991 $14,120 $623
The notices of deficiency for 1988, 1989, and 1991 were sent
by certified mail and were addressed to petitioner at 1554 Summit
Avenue, Hillside, New Jersey 07205 (the Summit Avenue address).
Each such notice was returned to respondent by the Postal Service
marked "unclaimed".
Respondent's records do not indicate that a notice of
deficiency was sent to petitioner for the taxable year 1990.
Petitioner filed income tax returns claiming refunds for the
following taxable years on the indicated dates:
Year Date Filed Refund Claimed
1988 10/21/92 $1,725
1989 06/20/94 7,317
1990 07/02/96 1,254
1991 11/19/96 10,650
Petitioner did not file an income tax return for the taxable
year 1992.
Petitioner's 1988 and 1989 income tax returns listed the
Summit Avenue address as petitioner's address. Petitioner's 1990
and 1991 income tax returns listed a different address; namely,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011