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Respondent initiated an examination of petitioner's taxable
years 1987 through 1992 in April 1993. Respondent attempted to
contact petitioner in that regard by letter dated December 15,
1993. This letter was mailed to petitioner at 2254 Ptarmigan
Lane, Colorado Springs, CO 80918-1410 (the Colorado Springs
Address). The letter was returned to respondent by the Postal
Service on January 6, 1994, bearing the notation "forwarding
order expired".
At the time that respondent sent the letter dated December
15, 1993, the Federal income tax return most recently filed by
petitioner was for the taxable year 1986. That return listed the
Colorado Springs Address.
On January 11, 1994, respondent made another attempt to
contact petitioner. In this regard, respondent mailed a letter
to petitioner at 16185 N. County Road, Nathrop, CO 81236-9703
(the Nathrop Address).2 The Nathrop Address was the address of
petitioner's parents. This letter was returned to respondent by
the Postal Service on January 14, 1994, bearing the notation
"returned to sender". Apparently, petitioner's parents returned
all mail addressed to their son.
2 At the same time, respondent also mailed another copy of
this letter to an address that appears to be a variation of the
Nathrop Address; i.e., 16185 County 162 Rd, Nathrop, CO 81236.
This letter was returned to respondent by the Postal Service
bearing the notations "returned to sender" and "attempted, not
known".
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