Deborah F. Robinson - Page 11

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          address.9  Surely petitioner must have realized that respondent             
          was likely to use the address appearing on her returns in                   
          corresponding with her.  And surely petitioner must have realized           
          that respondent was likely to use the address appearing on her              
          returns in issuing her a refund check.10  After all, it was "for            
          security reasons" that petitioner allegedly notified respondent             
          of a change of address.                                                     
               Fourth, in corresponding with respondent, petitioner                   
          continued to use the Summit Avenue address as late as November              
          1995.  Thus, correspondence attached to petitioner's motion to              
          restrain shows that petitioner used the Summit Avenue address in            
          letters dated June 15, 1991, October 5, 1992, October 18, 1992,             
          December 12, 1992, March 14, 1995, July 23, 1995, October 4,                
          1995, and November 15, 1995.                                                
               Fifth, based on petitioner's motion to restrain, petitioner            
          first used the P.O. Box 5072 address in January 1994 and then not           
          again until late November 1995.  Between those times, petitioner            
          used the Summit Avenue address in letters to respondent dated               



               9  It will be recalled that petitioner's tax returns for               
          1988, 1989, 1990, and 1991 were filed on Oct. 21, 1992, June 20,            
          1994, July 2, 1996, and Nov. 19, 1996.  Thus, all four returns              
          listing the Summit Avenue address were filed after the purported            
          letter dated Apr. 10, 1988, and the purported letter dated Mar.             
          3, 1989.                                                                    
               10  It will be recalled that petitioner's tax returns for              
          1988, 1989, 1990, and 1991 claimed refunds in the amounts of                
          $1,725, $7,317, $1,254, and $10,650, respectively.                          




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